ARTICLE
13 February 2017

New York State Department Of Financial Services Announces That Anti-Terrorism Transaction Monitoring And Filtering Program Regulation Is In Effect

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A&O Shearman

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A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
On January 5, 2017, the NYSDFS Superintendent Maria T. Vullo announced that the Department's transaction monitoring and filtering program regulation took effect as of January 1st.
United States Finance and Banking

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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