State-chartered financial institutions in New York are struggling to identify who among their senior-level employees should attest to the efficacy of their compliance programs under a regulation taking effect in January. In June, the New York State Department of Financial Services (NYSDFS) issued a final rule requiring all banks, money transmitters and other institutions chartered by the state to assess their potential exposure to financial criminals and ensure that their sanctions and anti-money laundering (AML) compliance programs are "reasonably designed" to manage those risks. The final rule includes several significant revisions to what the state proposed in December but still...