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The below article is part 4 of a 4 part series.
As with proposed rules issued by federal agencies, New York must also include a regulatory impact statement with its proposals. According to the state, the proposed regulation is intended to prevent money launderers, terrorists, and other tortfeasors from using the financial system to further their criminal activities. Although the state knows that the Bank Secrecy Act and the OFAC regulations have the same purpose, the state believes that its rule creates a more granular framework for a chief compliance officer or their functional equivalent to follow in designing, implementing, and maintaining a program that complies with the state law.
The state further believes that this rule does not change existing compliance requirements, but rather, it ensures that compliance officers are proactive in their duties to comply with both federal and state AML laws. Finally, the state believes that those institutions that have been in compliance with federal statutes in the past will have no increase in costs, and only those institutions which have a system that is not in compliance will incur more expense.
For banks, savings banks, and savings associations in New York, it would seem that these institutions will be spending a lot of time and money testing and retesting their systems to ensure that their chief compliance officers can stay out of harm’s way and certify that the institutions are in compliance with the requirements of the law.
Read on, download the full PDF, Emerging State Anti-Money Laundering Issues [As modeled by the state of New York]
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If you missed any of the series check out the article(s) below:
Emerging State Anti-Money Laundering Issues: Introduction
Emerging State Anti-Money Laundering Issues: Summary of Proposed Rule
Emerging State Anti-Money Laundering Issues: Transaction Monitoring and Filtering Program Requirements