Compliance with New Anti-Money Laundering Requirements in New York State

Bruce Ortwine, General Counsel, Americas; Adviser, Global Legal and Compliance; Senior Executive Vice President, Sumitomo Mitsui Trust Bank, Limited, USA

Anti-money laundering requirements, specifically those prohibiting the funding of countries and entities subject to U.S. sanctions laws, continue to be a top priority of bank regulatory agencies in the United States. The New York State Department of Financial Services (the “NYSDFS”) has emerged in recent years as especially aggressive in its enforcement of these requirements. A recent regulation (“Part 504”), issued by the NYSDFS, requires that banks annually certify their compliance with strict and comprehensive provisions relating to systems that monitor account transaction activities and funds transfer activities that are intended to identify suspicious activity and prevent transfers to sanctioned countries and entities. Part 504 is the most comprehensive of its kind in the U.S. My bank recently completed a process to confirm its adherence to the requirements of Part 504 and to so certify its compliance.

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USA Compliance Banking & Finance April 2018 Vol.11, No. 43, Spring 2018

Bruce Ortwine

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General Counsel, Americas, Advisor, Global Legal and Compliance and Senior Executive Vice President for Sumitomo Mitsui Trust Bank, Limited

Sumitomo Mitsui Trust Bank, Limited

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SMTB is the largest trust bank in Asia and a major international bank with offices throughout Asia, Europe and the U.S..

USA Compliance Banking & Finance April 2018 Vol.11, No. 43, Spring 2018