NYDFS Issues Final Rule on Transaction Monitoring and Filtering Programs
Client Memorandum

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The New York State Department of Financial Services (“DFS”) issued a Final Rule on June 30, 2016 requiring regulated institutions to maintain “Transaction Monitoring and Filtering Programs” reasonably designed to (i) monitor transactions after their execution for compliance with the Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) laws and regulations, including suspicious activity reporting requirements; and (ii) prevent unlawful transactions with targets of economic sanctions administered by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”).  These requirements go into effect on January 1, 2017, and regulated institutions are required to file their first annual compliance certification by April 15, 2018