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Financial Services Law Insights and Observations

New York Bank Regulator Considering Cybersecurity Regulations, Random Audits of Banks

Anti-Money Laundering Bank Supervision Privacy/Cyber Risk & Data Security NYDFS

Privacy, Cyber Risk & Data Security

On February 25, New York DFS Superintendent Benjamin Lawsky delivered remarks at Columbia Law School focusing on how state bank regulators can better supervise financial institutions in a post-financial crisis era.  In his remarks, Lawsky stated that “real deterrence” to future misconduct “means a focus not just on corporate accountability, but on individual accountability” at the senior executive level. Lawsky also highlighted measures that DFS is considering to prevent money laundering including conducting random audits of regulated firms’ “transaction monitoring and filtering systems” and making senior executives attest to the adequacy of the systems. Lastly, Lawsky outlined several cybersecurity initiatives and considerations that would require third-party vendors to have cybersecurity protections and regulations in place that would mandate the use of “multi-factor authentication” systems for DFS regulated firms.