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NY Anti-terrorism, Anti-money Laundering Regulation in Effect

Tue 10 Jan, 2017  /  by McIntyre & Lemon  /   Client Alerts

01/10/17 –  New York Department of Financial Services’ (NYDFS) risk-based anti-terrorism and anti-money laundering regulation is now in effect.

As of January 1, 2017, NYDFS regulated institutions are required to maintain programs to monitor and filter transactions for potential Bank Secrecy Act (BSA) and anti-money laundering (AML) violations and prevent transactions with sanctioned entities, as well as certify compliance with the regulation annually to DFS.

The new rule requires relevant regulated institutions to review transaction-monitoring and filtering programs and ensure that such programs are designed to comply with regulatory safeguards. The institutions also must adopt either an annual board resolution or senior officer compliance finding to certify compliance with the DFS regulation beginning April 15, 2018. The resolution or finding must state that documents, reports, certifications and opinions of officers and other relevant parties have been reviewed by the board of directors or senior official to certify compliance with the regulation.

In preparation for the regulation’s effective date, NYDFS has provided comprehensive training for all its bank examiners and has updated examination “first-day letters” to reflect the additional provisions that the new regulation requires.

NYDFS Press Release.