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ARTICLE · 09 JANUARY 2017

New York Mandates Economic Sanctions Compliance Program

The New York rule became effective January 1, 2017.

United StatesFinance and Banking

The New York rule became effective January 1, 2017.

The New York State Department of Financial Services (DFS) has issued a regulation that requires certain New York regulated financial institutions to maintain programs to monitor and filter transactions for potential Bank Secrecy Act (BSA), anti-money laundering (AML) violations, and to prevent transactions with sanctioned entities. The rule, which became effective January 1, is Part 504 of DFS Superintendent's Regulations [Rule] and details which institutions subject to DFS jurisdiction must comply. This regulation "will be enforced pursuant to [DFS'] authority under any applicable laws." It is thus possible that violation of the rule could lead to penalties under New York's banking and penal laws for falsifying business records, offering a false statement for filing, or failing to maintain accurate books and records.

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