Contract analysis

1. Retail Banking — All consumer deposit accounts, consumer lending, and consumer payment services offered directly by BRB.

2. Commercial Lending — All commercial and industrial lending, commercial real estate lending, and treasury management services offered by BRB to business customers.

3. Wealth Management — All investment advisory, trust, and fiduciary services offered by BRB's wealth management division.

4. Banking-as-a-Service (BaaS) Fintech Partnerships — All transactions, accounts, and services originated or processed through BRB's 14 active BaaS fintech partners operating under BRB's national banking charter. This Manual covers all transaction types processed by or through BRB, including: • Wire transfers, both domestic (Fedwire) and international (SWIFT/CHIPS); • Automated Clearing House ("ACH") transactions, in

1. Specially Designated Nationals and blocked Persons List (SDN List) — The primary OFAC list identifying individuals, entities, vessels, and aircraft whose property and interests in property are blocked.

2. Consolidated Sanctions List — The aggregated list combining the SDN List and other OFAC-administered lists.

3. Sectoral Sanctions Identifications List (SSI List) — Identifying persons operating in specified sectors of the Russian economy subject to sectoral sanctions.

4. Foreign Sanctions Evaders List (FSE List) — Identifying foreign persons who have been determined to have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions against specified countries.

5. Non-SDN Palestinian Legislative Council List (NS-PLC List) — Identifying members of the Palestinian Legislative Council who were combatants or combatants in the January 2006 elections.

6. Correspondent Account or Payable-Through Account Sanctions List (CAPTA List) — Identifying foreign financial institutions subject to correspondent or payable-through account sanctions.

7. Non-SDN Communist Chinese Military Companies List (NS-CMIC List) — Identifying Communist Chinese military companies subject to certain prohibitions on securities transactions.

8. Non-SDN Menu-Based Sanctions List (NS-MBS List) — Identifying persons subject to certain menu-based sanctions imposed under various executive orders. OFAC publishes updates to these lists on a rolling basis, without a fixed or predictable schedule. List updates may occur at any time, including additions of new designations, modifications to existing entries, and removals (delistings). It is imperative that BRB's s

1. List Version Number Confirmation: The OFAC Screening Unit verifies that the list version number reflected in the Veridian system matches the most recently published version number on OFAC's website (OFAC.gov).

2. Date Stamp Verification: The OFAC Screening Unit confirms that the list date stamp in the Veridian system reflects the most recent OFAC publication date.

3. Record Count Comparison: The OFAC Screening Unit compares the total number of records in the ingested list against the record count published by OFAC to ensure completeness. Any discrepancy in record count triggers an immediate investigation.

4. System Log Review: The OFAC Screening Unit reviews the Veridian system's automated list update logs to confirm successful ingestion, including the timestamp of the update, any error messages, and confirmation of list activation within the screening engine. Any list update delay exceeding 24 hours from the time of OFAC publication constitutes a critical compliance event and triggers immediate escalation to the BSA

1. At Application: OFAC screening is performed upon receipt of the loan application, using the applicant's name and identifying information.

2. At Disbursement: OFAC screening is performed again immediately prior to loan disbursement, to capture any changes to OFAC lists that may have occurred between application and disbursement. Screening at both the application and disbursement stages is required for all loan types, including commercial loans, consumer loans, residential mortgage loans, and BaaS partner-originated loans. In addition to screening the pr

1. Transaction Type: Wire transfer hits receive the highest priority, followed by ACH transaction hits, followed by card transaction and other transaction type hits. The priority order reflects the relative speed of settlement and the greater difficulty of recovering funds once a wire transfer has been executed.

2. Dollar Amount: Transactions above $50,000 are prioritized over lower-value transactions, reflecting the greater potential sanctions compliance impact of higher-value transactions.

3. Country Risk: Transactions involving countries or jurisdictions identified as high-risk for sanctions purposes — including comprehensively sanctioned countries and countries with significant sanctions evasion risks — are prioritized for review.

4. BaaS Partner Risk Tier: Hits associated with the top three BaaS partners by volume — NovaPay, FairLend Digital, and VaultEdge — are flagged for priority review. This prioritization reflects the volume concentration of these partners and the heightened regulatory focus on BaaS-related screening following the Consent Order. All hits must be assigned to an analyst within 1 hour of generation during normal business ho