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Contract analysis / email-hartmann-to-frey-occ-rap-submission.eml
email-hartmann-to-frey-occ-rap-submission.eml
High · 1
Medium · 0
Standard · 0
1. Cover Letter to the OCC Transmitting the Remediation Action Plan
1. Cover Letter to the OCC Transmitting the Remediation Action Plan
2. Comprehensive Remediation Action Plan (master document)
2. Comprehensive Remediation Action Plan (master document)
3. RAP Executive Summary (board-level summary)
3. RAP Executive Summary (board-level summary)
4. Workstream 1: OFAC Sanctions Screening Remediation Plan — addressing OFAC screening gap
4. Workstream 1: OFAC Sanctions Screening Remediation Plan — addressing OFAC screening gaps across BRB's Banking-as-a-Service ("BaaS") channels, including approximately 3.8 million of 31.7 million NovaPay transactions (approximately 12%) that were not screened against OFAC lists during calendar year 2023; full OFAC screening operationalization is targeted for November 1, 2025
5. Workstream 2: SAR Backlog Clearance & Process Improvement Plan — addressing the backlog
5. Workstream 2: SAR Backlog Clearance & Process Improvement Plan — addressing the backlog of approximately 2,400 unreviewed alerts and the reduction of average SAR filing time from 78 days toward the 30-day regulatory benchmark; SAR backlog clearance is targeted for June 30, 2025
6. Workstream 3: CDD/EDD Remediation Plan — addressing approximately 47,000 high-risk cust
6. Workstream 3: CDD/EDD Remediation Plan — addressing approximately 47,000 high-risk customer accounts lacking adequate Customer Due Diligence and Enhanced Due Diligence documentation, with a 50% milestone (approximately 23,500 accounts) by July 15, 2025 and 100% completion by January 15, 2026
7. Workstream 4: Transaction Monitoring Model Validation & Tuning Plan — addressing the Ve
7. Workstream 4: Transaction Monitoring Model Validation & Tuning Plan — addressing the Veridian TMS v.10.0 system upgrade, with User Acceptance Testing completion targeted for August 1, 2025 and independent model validation by October 1, 2025
8. Workstream 5: BSA/AML Program Governance & Training Enhancement Plan — addressing board
High
⚑ Penalty / liquidated damages
8. Workstream 5: BSA/AML Program Governance & Training Enhancement Plan — addressing board-level oversight deficiencies, establishment of a dedicated Compliance Committee, organizational restructuring of the compliance function, and enterprise-wide BSA/AML training **Scope of the Remediation Action Plan** The RAP addresses all five core deficiency categories identified in the Consent Order: (i) OFAC sanctions screeni
1. Cover Letter to OCC Transmitting Remediation Action Plan
1. Cover Letter to OCC Transmitting Remediation Action Plan
2. Comprehensive Remediation Action Plan
2. Comprehensive Remediation Action Plan
4. Workstream 1: OFAC Sanctions Screening Remediation Plan
4. Workstream 1: OFAC Sanctions Screening Remediation Plan
5. Workstream 2: SAR Backlog Clearance & Process Improvement Plan
5. Workstream 2: SAR Backlog Clearance & Process Improvement Plan
6. Workstream 3: CDD/EDD Remediation Plan
6. Workstream 3: CDD/EDD Remediation Plan
7. Workstream 4: Transaction Monitoring Model Validation & Tuning Plan
7. Workstream 4: Transaction Monitoring Model Validation & Tuning Plan
8. Workstream 5: BSA/AML Program Governance & Training Enhancement Plan
8. Workstream 5: BSA/AML Program Governance & Training Enhancement Plan