NYDSF Rule 504 Certification
Logical, structured, disciplined and systematic.
Sustainable & repeatable.
Scalable & suitably-Sized.
Experience and expertise.
Objective and independent.
Proven Risk-Based & Sustainable Program Testing Methodology, Process and supporting automated tools.
Validates alignment and conformity with AML Risk Assessment and applicable local, regional & group level rules, regulations, policies and procedures.
Identifies & documents data, watch lists, filters, scenarios, model & rule monitoring coverage, thresholds & tunable parameters, segmentation/ population groups and alert risk scoring gaps, issues, concerns, and control weaknesses.
We recognize the overlap & similarities between Rule 504 Program Certification and OCC 2011-12 Model Validation Framework. We incorporate & leverage those overlaps wherever they’re fit.
Expertly documented current program state & status, controls, gaps and associated risks, continuous improvement roadmap, recommended changes, and remediation steps.
Rule 504 Annual Program Certification Timeline
Each Regulated Institution must certify compliance with Rule 504, Part 3 (a), (b), (c) and (d):
(a) “Each Regulated Institution shall maintain a Transaction Monitoring Program reasonably designed for the purpose of monitoring transactions after their execution for potential BSA/AML violations and Suspicious Activity Reporting, which system may be manual or automated…”
(b) “Each Regulated Institution shall maintain a Filtering Program, which may be manual or automated, reasonably designed for the purpose of interdicting transactions that are prohibited by OFAC…”
(c) “Each Transaction Monitoring and Filtering Program shall require the following, to the extent applicable… 3. Data Sources, Data Integrity, 4. Governance and Management oversight, including policies and procedures governing Changes to the Transaction Monitoring and Filtering Program….5. Vendor Selection process: If a third party vendor is used to acquire, install, implement, or test the Transaction Monitoring and Filtering Program or any aspect of it; 6. Funding to design, implement and maintain a Transaction Monitoring and Filtering Program that complies with the requirements of this Part; 7. Qualified personnel or outside consultant(s) responsible for the design, planning, implementation, operation, testing, validation, and on ‐ going analysis of the Transaction Monitoring and Filtering Program, 8. Training…”
(d) Continuous Improvement Programme – material improvement, updating and re-design.
Vesta Compliance Solutions, LLC - NYDFS Rule 504 - Annual Program Certification Steps
To request NYDFS Rule 504 Service Offering information or meeting, or, to ask additional Rule 504 Program Certification questions please contact Vesta Compliance Solutions, LLC Rule 504 Program Coordinators.