Introduction
The New York Department of Financial Services
("NYDFS") recently promulgated a highly-anticipated
regulation, to become effective January 1, 2017, imposing new
anti-money laundering, anti-terrorism, and economic and trade
sanctions requirements on financial institutions regulated by the
NYDFS (the "Final Rule").1 The Final Rule is
the latest example of the NYDFS' increased activity in the
BSA/AML arena, following several years of enhanced supervision and
enforcement of Bank Secrecy Act/anti-money laundering laws
("BSA/AML") as well as the economic and trade sanctions
administered by the U.S. Department of the Treasury's Office of
Foreign Assets Control ("OFAC"). As result of such
actions, NYDFS has indicated that it "has reason to believe
that financial institutions have shortcomings in their transaction
monitoring and filtering programs."2 The Final
Rule, therefore, imposes regulatory requirements for all
institutions operating in New York and
