A December 2016 New York Department of Financial Services (DFS) consent order with a European bank and its New York Branch warrants a second look.
This consent order provides a platform for the DFS to justify and reinforce its commitment to its newly enacted Part 504, Transaction Monitoring and Filtering Program Requirements and Certifications. In the introduction to the consent order, the DFS emphasizes trends in Part 504: "...significant shortcoming in transaction monitoring and filtering programs of a number of major financial institutions...generally were attributable to a lack of robust governance, oversight, and accountability at senior levels. These findings have…led the Department to issue a new regulation (effective January 1, 2017) governing transaction monitoring and filtering systems..."