“Is this us?” When it comes to penalty actions that include insufficient resources, that is one of the first questions the average AML compliance officer should ask after reading some of the more recent enforcement cases, like the one that resulted in an $8 million penalty for Raymond James, or the $16.5 million headache for Credit Suisse. […]
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 first reporting date of April 15, 2018. In a sense, the Rule follows upon the […]
