On January 5, 2017, the New York State Department of Financial Services (NYSDFS) Superintendent Maria T. Vullo announced that the Department's transaction monitoring and filtering program regulation took effect as of January 1st. Under the final regulation, institutions regulated by the NYSDFS must: maintain programs to monitor and filter transactions for potential Bank Secrecy Act and anti-money laundering violations and suspicious activity reporting; maintain a filtering program to prevent transactions that are prohibited by the Office of Foreign Assets Control; and submit a confirmation to the NYSDFS regarding compliance with the final rule.

The Shearman & Sterling client alert on the final rule is available at: http://www.shearman.com/en/newsinsights/publications/2016/07/monitoring-of-ny-state-licensed-institutions.

The press release is available at: http://www.dfs.ny.gov/about/press/pr1701051.htm.

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