Arnold & Porter explains New York Takes Lead on Anti-Terrorism and Anti-Money Laundering Enforcement by Proposing Criminal Liability for Compliance Officers

On December 1, 2015, the New York Department of Financial Services (the DFS) released a proposed rule that would require certain New York-regulated financial institutions (Regulated Institutions) to comply with enhanced anti-terrorism and anti-money laundering (AML) requirements and subject chief compliance officers to potential criminal liability for noncompliance (the Proposal).

The proposed regulations aim to strengthen New York financial institutions’ fight against terrorist financing and money laundering at a time when terrorism concerns are at their highest in years. The Proposal, which was developed by the DFS over several months, also comes amid persistent calls from the general public to … Read more