If you’re a fashion fanatic and you want to get a jump on what will be hot next season, you’d probably want to look to the current fashion trends in New York. After all, New York, New York is known as one of the fashion capitals of the world. Now, if you’re in charge of BSA/AML compliance at your financial institution, your regulators will not be amused if you’re behind on anti-money laundering efforts, even if your compliance team looks ready to walk the runway. They’ll expect you to make sure that your institution is dressed in the latest and greatest practices, procedures, and equipment to detect and monitor suspicious activity. To do a good job of that, it’s helpful to know what’s on the horizon for anti-money laundering efforts.
Like future fashion trends, the future of financial regulation can often be seen in recent regulatory changes from New York, as well as certain states like California. Oftentimes, regulatory updates from these states set a precedent for federal regulations (think UDAAP and the Servicemembers Civil Relief Act).
Last year, New York State regulators released a final anti-terrorism and anti-money laundering regulation that requires institutions to maintain programs to monitor and filter transactions for potential Bank Secrecy Act (BSA) and anti-money laundering (AML) violations and prevent transactions with sanctioned entities. The regulation went into effect earlier this year and those changes will certainly be watched by many groups including, no doubt, federal regulators. For BSA, while you may not be subject to the specific New York changes, it makes a lot of sense to evaluate yourself against these heightened standards…
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