MEMORANDUM

TO: All New York Bank Regulated Institutions & New York Licensed Check Cashers & Money Transmitters)

FROM: Superintendent Maria T. Vullo

DATE: March 16, 2018

RE: April 16, 2018 Transaction Monitoring Regulation Certification Filing Deadline

This is to remind all New York chartered banks, trust companies, private bankers, savings banks, and savings and loan associations chartered pursuant to the New York Banking Law, and all branches and agencies of foreign banking corporations licensed pursuant to the New York Banking Law, and all check cashers and money transmitters licensed pursuant to the New York Banking Law, that they are covered entities under Part 504, the Department of Financial Services’ (the ‘Department’) Transaction Monitoring regulation.

The first certification of compliance is due on or before April 16, 2018.¹ This certification must be filed electronically via the Department’s Transaction Monitoring portal, which will be available starting the week before the April 16 deadline. Based on our records, your institution is a covered entity and is required to file.

The goal of the Department’s regulation is to require covered institutions to have transaction monitoring and filtering systems in compliance with the requirements of the regulation. New York’s Transaction Monitoring regulation became effective January 1, 2017.

The DFS web site contains a copy of the Transaction Monitoring regulation: http://www.dfs.ny.gov/legal/regulations/adoptions/dfsp504t.pdf; and a set of frequently asked questions concerning the regulation: http://www.dfs.ny.gov/legal/dfs/trans_monitor_faqs.htm

¹ April 15, 2018 falls on a Sunday.