Compliance officers looking for helpful “ripped-from-the-headlines” enforcement actions to support their requests for resources and direct access to the board need look no further than the recent $30‑million fine from the New York Department of Financial Services on the cryptocurrency trading unit of online brokerage firm Robinhood Markets, Inc. The consent order for the NYDFS’ first crypto enforcement action describes deficiencies in the compliance culture, violations of a host of virtual currency, AML/BSA, financial services, and cybersecurity regulations, and highlights Robinhood’s hyper-fast growth and reliance on the parent company’s (also inadequate) compliance systems and resources as potential factors in their failures. We discuss the alleged failures and provide insights on the consent order’s implications from partners at Skadden and Greenberg Traurig. See “The Evolving Crypto Regulatory Climate
” (May 11, 2022).