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New York Banks Face New Anti-Money Laundering Compliance Requirements, Effective January 1

National Law Review

In this article, Joseph Rillotta examines regulations recently adopted by the New York Department of Financial Services (DFS), effective January 1, 2017, which create new transaction monitoring and filtering requirements for New York Banks to ensure compliance with the Bank Secrecy Act (BSA), anti-money laundering (AML) regulations, Department of Treasury Office of Foreign Asset Controls (OFAC) rules, and related provisions of law. These regulations also require each subject bank to submit an annual certification of compliance, signed by the bank's board of directors or by a designated senior officer, with first such certifications due April 15, 2018. While DFS's final rule took a more moderate approach in response to concerns raised during the comment period, the final regulations still create a host of new requirements, and they present new risks for bank directors and officers.