On June 30, 2016, the New York State Department of Financial Services (“NYS DFS”) issued the final version Rule 504, “Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications.” The Rule takes effect on January 1, 2017, with the … Read More
A Brief Summary Oddly, despite its significance in the BSA/AML/CFT/OFAC Compliance universe, the BSA Risk Assessment has no statutory requirement even though it is the foundation of any Compliance Program. As compliance professionals, we construct our transaction monitoring systems, OFAC … Read More
For foreign branches conducting business in the U.S., head office can sometimes be both Dr. Jekyll and Mr. Hyde. On occasion this has proved to be a problem. At times banks are faced with a bureaucracy of business, which can … Read More