FILING UPDATE: NYDFS Affirms ACC’s Position Against Criminal Liability for Compliance Officers


ACC Position: 

The New York Department of Financial Services (NYDFS) affirmed ACC’s position on criminal liability for compliance officers in recently released anti-money laundering regulations. NYDFS significantly changed the compliance officer certification requirements, to which ACC had objected in a comment letter filed with the agency in March 2016.

The final, adopted regulations from NYDFS can be viewed here.