Compliance officers at financial institutions located in the State of New York are most likely familiar with the new BSA/AML/CFT regulations, promulgated by the very proactive New York State Department of Financial Services (DFS), which became law on January 1, 2017 but for those in other jurisdictions, it may be best for you to examine them at this time. Other states are certainly looking at them, and similar regulations could be enacted elsewhere in the near future.
Readers who wish to access the complete text of part 504, the Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications may be viewed here.
Contributed by Kenneth Rijock
Journals of Monte Friesner