13 Dec 2016
In the post-Yates Memo landscape, increasing attention is being paid to high-level individuals within business entities under government scrutiny. Yet another example of this trend are 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 the first such certifications due April 15, 2018. While DFS softened the proposed rules in several respects 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.
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