Money Transfer

Transaction Monitoring

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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 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. If you don’t already have a DFS portal account, you will need to create one. Instructions can be found on the Portal.

Questions?

Questions related to Transaction Monitoring filings should be directed to your supervisory point of contact.