# DFS Virtual Currency Customer Service Guidance (May 2024): Guidance Regarding Customer Service Requests and Complaints (Virtual Currency Entities)

Source: https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-industry-letter-2024-05-30-vce-customer-service
Last updated: Aug 26, 2026

DFS's May 30, 2024 Industry Letter to virtual currency entities is its only guidance so far that sets rules for AI chatbots in customer service. Where a firm uses AI in customer service it must tell the customer at the start of the interaction that they are dealing with an AI tool and not a human, must let the customer escalate any request or complaint to a human representative, and must test and monitor the tool to ensure the information it gives is accurate. Acting Superintendent Asrow cited it to the Assembly in December 2025 as part of DFS's AI record.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [NY DFS](https://www.bankingnewsai.com/ai-regulation/ny-dfs) |
| Type | Letter |
| Status | In force |
| Published | May 30, 2024 |
| Effective | May 30, 2024 |
| Applies to | DFS-licensed or -chartered virtual currency entities (BitLicensees and limited-purpose trust companies); a signal of DFS expectations for AI customer-service tools more broadly |
| Official text | https://www.dfs.ny.gov/industry-guidance/industry-letters/il20240530-cus-serv-req-and-complains |

## Key points

- AI disclosure: customers must be informed at the beginning of the interaction that they are using an AI tool, not a human customer service representative.
- Human escalation: any request or complaint must be escalable from the AI tool to a human customer service representative.
- Accuracy: the firm must conduct sufficient testing and monitoring of any AI tool to ensure the information provided to customers is accurate.
- Baseline channels: at minimum a phone number and an electronic text channel (email or chat) for requests and complaints.
- Quarterly tabulation, starting with Q3 2024, of requests and complaints by channel and average time to resolution, to be made available to DFS.
- Scope is limited to virtual currency entities, but the three chatbot conditions mirror the CFPB's June 2023 chatbot findings and are the clearest statement of what DFS expects from any regulated firm's AI customer-service deployment.

## What changed for banks

Before this letter DFS had no written expectations on AI chatbots; afterward, AI disclosure, human escalation, and accuracy testing became documented DFS positions that examiners of banks and money transmitters can reference by analogy. Bank digital-channel teams deploying generative-AI assistants in New York generally treat these three conditions as a floor.

## Use cases it governs

- [Customer-facing chatbots](https://www.bankingnewsai.com/ai-regulation/by-use-case#customer-chatbots)
- [Generative & agentic AI](https://www.bankingnewsai.com/ai-regulation/by-use-case#generative-agentic-ai)
- [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general)

## FAQ

### Does NYDFS require disclosure that a customer is talking to an AI chatbot?

For virtual currency entities, yes: the May 30, 2024 guidance requires telling the customer at the start of the interaction that they are using an AI tool, offering escalation to a human, and testing the tool for accuracy. No equivalent binding statement exists yet for banks, but DFS cites this letter as its AI-in-customer-service position.

### Does the VCE customer service guidance apply to banks?

No; it is addressed to DFS-licensed virtual currency entities. Banks should read it as a signal of DFS expectations, alongside CFPB chatbot guidance and UDAP principles.

## Related documents

- [DFS Frontier AI Models Industry Letter (May 2026)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-industry-letter-2026-05-21-frontier-ai-models) — Heightened Cybersecurity Risks Associated with Frontier AI Models (May 21, 2026)
- [DFS Heightened Threat Environment Guidance (May 2026)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-industry-letter-2026-05-21-heightened-threat-environment) — Guidance on Measures Regulated Entities Should Consider in a Heightened Cybersecurity Threat Environment (May 21, 2026)
- [New York RAISE Act](https://www.bankingnewsai.com/ai-regulation/documents/ny-raise-act) — Responsible AI Safety and Education (RAISE) Act, General Business Law Article 44-B (Chapter 699 of the Laws of 2025, as amended by Chapter 96 of the Laws of 2026) (Dec 19, 2025)
- [Asrow Assembly Statement on AI in Insurance (Dec 2025)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-asrow-assembly-statement-2025-12-16-ai-insurance) — Statement by DFS Acting Superintendent Kaitlin Asrow at the NYS Assembly Hearing on the Use of Artificial Intelligence Systems in Insurance Underwriting and Pricing (Dec 16, 2025)
- [DFS AI Cybersecurity Industry Letter (Oct 2024)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-industry-letter-2024-10-16-ai-cyber-risks) — Cybersecurity Risks Arising from Artificial Intelligence and Strategies to Combat Related Risks (Oct 16, 2024)
- [Insurance Circular Letter No. 7 (2024)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-insurance-circular-letter-2024-07) — Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing (Jul 11, 2024)
- [DFS Proposed AI Insurance Circular Letter (Jan 2024)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-proposed-insurance-circular-letter-2024-01) — Proposed Insurance Circular Letter on the Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing (Jan 17, 2024)
- [23 NYCRR Part 500](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-23-nycrr-part-500) — Cybersecurity Requirements for Financial Services Companies (Second Amendment) (Nov 1, 2023)

Last reviewed Aug 26, 2026. Cite the official text (https://www.dfs.ny.gov/industry-guidance/industry-letters/il20240530-cus-serv-req-and-complains) for the rule and this page for the summary and dates.

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