As of 1 January 2017, new sanctions compliance rules agreed by New York’s Department of Financial Services (NYDFS) last month will impose additional monitoring and certification requirements on the boards and senior management of financial institutions. The new rules will require New York financial institutions to tailor their sanctions and AML compliance programmes to the specific risks they face as a business, with robust oversight, maintenance, and third-party monitoring. In addition, every regulated financial institution will be required to certify annually that they have reviewed their compliance programmes to confirm that they meet the requirements of the new rules. This certification must be signed by the firm’s board of directors, equivalent body, or a sufficiently senior person responsible for compliance. NYDFS press release here.
Maya Lester QC is a senior barrister (Queen’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. The legal directories say she is the...See profile for Maya Lester QC >