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Can I store, hold, or maintain custody or control of virtual currency on behalf of others without obtaining a BitLicense?

Based on the information provided in the context documents, a person or entity cannot store, hold, or maintain custody or control of virtual currency on behalf of others in New York without obtaining a BitLicense [1.1][1.2]. According to 23 NYCRR 200.3, no person shall engage in any virtual currency business activity without a license obtained from the superintendent [1.2]. Therefore, a BitLicense is required to store, hold, or maintain custody or control of virtual currency on behalf of others in New York.It is important to note that a licensee must maintain a surety bond or trust account for the benefit of its customers in such form and amount as is acceptable to the superintendent for the protection of the licensee’s customers [1.1]. Additionally, to the extent a licensee stores, holds, or maintains custody or control of virtual currency on behalf of another person, such licensee shall hold virtual currency of the same type and amount as that which is owed or obligated to such other person [1.1].Furthermore, each licensee shall make, keep, and preserve all of its books and records in their original form or native file format for a period of at least seven years from the date of their creation and in a condition that will allow the superintendent to determine whether the licensee is complying with all applicable laws, rules, and regulations [1.4].In terms of consumer protection, each licensee shall disclose in clear, conspicuous, and legible writing in the English language and in any other predominant language spoken by the customers of the licensee, all material risks associated with its products, services, and activities and virtual currency generally, including at a minimum, the following: virtual currency is not legal tender, is not backed by the government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections [1.5].In summary, a BitLicense is required to store, hold, or maintain custody or control of virtual currency on behalf of others in New York. Additionally, licensees must maintain a surety bond or trust account for the benefit of its customers, hold virtual currency of the same type and amount as that which is owed or obligated to such other person, and keep all books and records for at least seven years. Finally, licensees must disclose all material risks associated with virtual currency to their customers.