http://www.dfs.ny.gov/about/press2014/pr1407171-vc.pdf
Quote
(m) Virtual Currency means any type of digital unit that is used as a medium of exchange or a form of digitally stored value or that is incorporated into payment system technology. Virtual Currency shall be broadly construed to include digital units of exchange that (i) have a centralized repository or administrator; (ii) are decentralized and have no centralized repository or administrator; or (iii) may be created or obtained by computing or manufacturing effort. Virtual Currency shall not be construed to include digital units that are used solely within online gaming platforms with no market or application outside of those gaming platforms, nor shall Virtual Currency be construed to include digital units that are used exclusively as part of a customer affinity or rewards program, and can be applied solely as payment for purchases with the issuer and/or other designated merchants, but cannot be converted into, or redeemed for, Fiat Currency;
I don't get it, on the one hand closed-loop gcs can't be redeemed for cash, but they could be sold on the sly by individuals without anyone noticing. Likewise, you can mess around with gaming currencies even though officially you can't redeem them for cash. Is Lawsky saying anything that gives an individual the freedom to send it to someone that isn't being tracked by the N$A, or is he saying it only includes companies that officially don't redeem your tokens for cash? I'd imagine that all specific companies would give up on the issuing of gift cards and ''partner'' with banks down the line. What do you think?