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ACAMS 18th Annual AML & Financial Crime Conference - Las Vegas

TUE16 - Update on Implementation Issues of DFS 504 Compliance

Sep 24, 2019 2:00pm ‐ Sep 24, 2019 3:15pm


• Reviewing cases to discern what “reasonably designed” transaction monitoring and OFAC sanctions filtering systems that address institutions’ specific risks require in practice

• Outlining strategies to deliver annual 504 certification including endorsement of board and confirming involvement of IT, internal audit and others in attaining effective monitoring

• Maintaining ongoing 504 compliance with policies such as comprehensive institutional risk assessments, end-to-end AML data validation and updating filtering as technology allows



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