Kenneth Rijock

Kenneth Rijock

Monday, July 4, 2016

NEW YORK ENACTS GROUNDBREAKING AML REGULATIONS


The New York State Department of Financial Regulation has finalized its landmark regulations on making senior management, and the compliance officer in command, strictly liable for AML/CFT/OFAC failures. It is anticipated that these new rules will be a game-changer, as other jurisdictions will most likely follow New York's lead, on a truly effective method of imposing personal liability for Anti-money Laundering deficiencies at financial institutions.

The new regulations, which go into effect on 2017, require annual board of directors resolutions, or a senior officer's officer's compliance finding confirming AML compliance. The AML program must:

(1) Maintain a Transaction Monitoring Program.
(2) Maintain a Watch List Filtering Program.
(3) Backed up by annual board of directors resolution or senior officer compliance finding.

Readers are urged to review the complete text* of the DFS regulations.
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*Banking Division Transaction Monitoring and Filtering Program requirements and Certifications


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