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NYDFS Proposes New Anti-Money Laundering Requirements, Liability for Compliance Officers
7 December 2015
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On December 1, 2015, New York Governor Andrew Cuomo announced proposed New York State Department of Financial Services (“NYDFS”) rules that would require New York- chartered and regulated banking institutions to enhance their Bank Secrecy Act (“BSA”)/anti-money laundering (“AML”) compliance programs.
The proposed rules place stringent requirements on covered institutions to adopt Transaction Monitoring and Watch List Filtering Programs and to certify annually that they maintain programs satisfying those requirements.
The annual certification would be done through a senior compliance officer who could face potential criminal penalties for filing an “incorrect or false” certification.
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Helen V. Cantwell
Satish M. Kini
David A. O'Neil
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