Superintendent of New York State Department of Financial Services (“NYDFS”), Maria T. Vullo, has focused the Department’s efforts on enforcement of New York’s Anti-Money Laundering (“AML”) laws. Since her confirmation on June 15, 2016, NYDFS has levied several fines, each over $150 million, against financial institutions operating in New York, and instituted new AML program requirements through a regulation that became effective on January 1, 2017. This Client Alert discusses three of the more significant fines issued by NYDFS and provides an overview of the new regulation.

Recent New York AML Fines Exceed $1B -

Over the last several months, NYDFS has levied fines against three large banks, the sum of which exceeds $600 million. Each of the fined banks also will be subject to ongoing independent oversight of some kind (e.g., in the form of an independent monitor or an independent consultant). The pace and size of these penalties represent an increase in activity for NYDFS with respect to AML enforcement.