Key takeaways

• On December 1, 2015, New York Governor Andrew Cuomo announced proposed New York State Department of Financial Services (“NYDFS”) rules that would require New York- chartered and regulated banking institutions to enhance their Bank Secrecy Act (“BSA”)/anti-money laundering (“AML”) compliance programs.
• The proposed rules place stringent requirements on covered institutions to adopt Transaction Monitoring and Watch List Filtering Programs and to certify annually that they maintain programs satisfying those requirements.
• The annual certification would be done through a senior compliance officer who could face potential criminal penalties for filing an “incorrect or false” certification.