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New York State Department of Financial Services: Part 504 Observations and Recommendations

Since the implementation, in January 2017, of the New York State Department of Financial Services (“DFS”) Part 504 Banking Division Transaction Monitoring and Filtering Program Requirements and Certification ("Part 504"), Sia Partners has observed how banks have been working to comply with it. 

In this article, we focus on some of the most challenging parts of Part 504, the strategies banks have been implementing to address them and the shortcomings they still have to solve. These shortcomings pertain to the banks’ risk assessment, inefficiencies in screening system, independent testing, data validation and governance processes. 

Below we discuss these and other deficiencies and provide associated recommendations to improve the soundness of bank’s Bank Secrecy Act (“BSA”) and Anti-Money Laundering (“AML”) framework to support their efforts to comply with Part 504.

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