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New York State of Mind: Model Validation and Section 504 - Sponsored by Arc-Serv

Panel (from left to right):

Lukas Babiak – BSA/AML Lead for International Banking Supervision out of New York, OCC

Meryl Lutsky, ACAMS New York Chapter Co-Chair (Moderator)

Maleka Ali – CAMS-AUDIT, President, Arc-Serv

Monica LaCroix-Rubin – SVP, Chief Compliance Officer, BNB Bank

Evan Weitz – Managing Director, Head of Controls, Europe and Americas, Financial Crime Compliance, Standard Chartered

On January 24, 2019, the ACAMS New York Chapter held a panel discussion with representatives from various financial institutions in addition to the perspectives of a consultant and a bank examiner. The event took place at Fordham University Law School and was sponsored by Arc-Serv.

February 15, 2019 will mark the one-year anniversary of the first certification for New York Department of Financial Services’ (NYDFS) AML rule (Part 504), which requires submission of annual certification of AML compliance. In light of this auspicious date the ACAMS New York Chapter, along with our event sponsor, organized a discussion to understand perspectives on what has gone well, what aspects of the requirement that may present difficulties, as well as some unintended results.

The discussion began with an introduction of basic requirements and expectations from NY DFS and the OCC from Maleka Ali. Ali provided an overview of required attributes for both Transaction Monitoring and Watchlist Filtering programs, as well as key next steps for institutions including updated risk assessments and further testing & validation. She additionally provided her perspectives and experiences from auditing small, mid-size and large financial institutions including common findings she has observed – most notably critical data issues.

Following the overview of the key certification (and supporting AML program) requirements, Lukas Babiak discussed his perspectives being a bank examiner. In his comments Babiak addressed OCC 11-12: Supervisory Guidance on Model Risk Management in relation to DFS 504 requirements.

The discussion was rounded out with the perspectives of the representatives from varying sized financial institutions on the panel. Some themes the speakers addressed were the fact that Section 504 has only formalized what were commonly understood as regulatory expectations, and that accountability within the organization has increased.

To that point, the panel representatives from financial institutions echoed similar structures in which sub-attestations are required to address the various components of the regulation and AML program operations. Examples discussed revolved around functions such as Training, Vendor Management, and Data Governance.

Event Materials: Slide deck



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