ETA Submits Comments to the NY Department of Financial Services Regarding Proposed Regulations of Transaction Monitoring and Filtering Systems Maintained by Banks
April 1, 2016
The Electronic Transactions Association hereby submits its comments in response to the Department of Financial Services’ proposal to adopt regulations designed to clarify the required attributes of the Transaction Monitoring and Filtering Program and Watch List Filtering Program maintained by regulated entities and to require a Senior Officer to certify on an annual basis that the entity’s programs comply with the new regulations. ETA is the leading trade association for the payments industry, representing over 500 companies that offer electronic transaction processing products and services. ETA’s members include financial institutions, licensed money transmitters and others that may be impacted by any rules or regulations the Department may adopt. ETA respectfully disagrees with the Department’s suggestion that the proposed rules are needed to foster compliance by regulated entities with federal anti-money laundering and sanctions requirements.