In this article, Litigation Member William Barry and Summer Associate Michelle Ramus discuss how to navigate the New York Department of Financial Services' (NYDFS) anti-money laundering (AML) compliance confirmation requirements. The law requires that regulated entities maintain transaction monitoring and watch list filtering programs consistent with Bank Secrecy Act (BSA) anti-money laundering (AML) requirements, and submit the annual confirmation in the form of either a Senior Officer compliance finding or a Board of Directors resolution. "In determining who the appropriate confirming person or entity should be, regulated institutions should develop a process that addresses concerns of potential personal exposure on the part of compliance officers and at the same time leverages the knowledge and experience of those most directly involved with the AML program," the authors wrote. Barry and Ramus discuss the requirements for the compliance finding or resolution and identify five best practices for developing a process that effectively utilizes both the Board of Directors' oversight function and the Senior Officer’s institutional knowledge, resulting in a finding or resolution process that is credible, supportable, and capable of repetition on an annual basis. "A thoughtful, documented approach and a clear process will go a long way toward assuring regulators, counterparties and personnel that the firm is well-positioned to succeed in this era of heightened scrutiny regarding AML and counter-terrorism financing," they wrote.