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
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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