On December 1, 2015, New York Governor Andrew Cuomo released a proposal for new anti-terrorism and anti-money laundering regulations for certain financial institutions. Among its more significant provisions is one that would require a Sarbanes-Oxley style annual certification to be signed by an institution’s Chief Compliance Officer, or an equivalent executive officer, that certifies to the institution’s compliance with the proposed regulations. The proposed regulations would also create requirements for financial institutions to implement and maintain a Transaction Monitoring Program and a Watch List Filtering Program. The proposed regulation will be published in an upcoming edition of the New York State Register, which will begin a 45-day comment period.

A copy of the proposed regulation can be found at: http://www.dfs.ny.gov/legal/regulations/proposed/rp504t.pdf.