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Transaction Monitoring Certification (504)
Regulated institutions must maintain programs to monitor and filter transactions for potential Bank Secrecy Act (BSA) and anti-money laundering (AML) violations, prevent transactions with sanctioned entities, and certify compliance with the regulation annually to DFS. Regulated institutions must submit the required certification covering the prior calendar year by April 15 of each year via the DFS Portal.
Please note that a regulated institution must file a certification even when, under 3 NYCRR 504.3(d), the regulated institution has documented the identification of, and the remedial efforts planned and underway to address, areas, systems, or processes that require material improvement, updating, or redesign.
Additional Documentation
A regulated institution should not submit any documents or records along with its certification – only the certification form itself should be submitted to DFS. However, 3 NYCRR 504.4 provides that the regulated institution shall maintain all documents and records necessary to support the certification, and that the Department may request such information at any time. For example, 3 NYCRR 504.3(d) provides that, to the extent a regulated institution has identified areas, systems, or processes that require material improvement, updating or redesign, the regulated institution must document such identification and remedial efforts planned and underway and maintain such schedules and documentation for inspection by the Department.
Submit your Certification of Compliance
The certification of compliance is submitted online through the DFS secure Portal.
Those conducting business on behalf of a regulated entity must use DFS ID to access the DFS Portal.
Users must receive an invitation to DFS ID from their Entity Administrator. You will use DFS ID credentials and multi-factor authentication (MFA) to log in, so be sure to have or download an authenticator app (e.g., Google or Microsoft Authenticator) to an available mobile device before getting started.
To get started, use the DFS Portal button below and sign in using your DFS ID credentials by choosing the first login option ("DFS ID Login")
Once logged in, use the "REQUEST APPS" tab and choose "Transaction Monitoring Certification (504)" to access the application.
- Learn more about DFS ID.
Questions?
Contact your Entity Administrator with questions regarding access to DFS ID. Questions related to Transaction Monitoring filings should be directed to your supervisory point of contact.