The State of New York Department of Financial Services, an agency that is not shy about going after financial institutions that are deficient in their AMLCFT programs, has proposed a massive set of new requirements for banks and MSBs, including what amounts to personal liability of their chief compliance officers, who will be certifying that their programs meet the new guidelines.
It is strongly suggested that you review the details of this proposed Part 504, Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications, because, when enacted, it will radically change what constitutes best practices in the field of the AML/CFT, since all financial institutions conducting business in New York would be forced to upgrade accordingly.
You can review the complete text here.
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