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Clifford Chance

Clifford Chance


The New York Department of Financial Services Finalizes Regulation 'Clarifying' Transaction Monitoring and Filtering Program Requirements

5 July 2016

On June 30, 2016, the New York Department of Financial Services (the "DFS") issued a final anti-money laundering ("AML") and counter-terrorist financing ("CTF") transaction monitoring and filtering programs regulation (the "Regulation").  While the final Regulation includes several amendments to the initial proposed regulation issued by the DFS on December 1, 2015 (the "Proposed Regulation"), the main substance of the proposed requirements has not changed.  The Regulation, which goes into effect January 1, 2017, both codifies heightened standards for transaction monitoring and filtering and imposes an annual compliance certification requirement on either the Board of Directors or Senior Officer(s). DFS-regulated institutions should promptly take steps to ensure that they are prepared to meet the new heightened standards prior to their effective date.

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