Contract analysis

I. Executive Summary This document sets forth a detailed remediation plan (the "OFAC Screening Remediation Plan" or "Workstream 1") that addresses all deficiencies in OFAC sanctions screening identified by the Office of the Comptroller of the Currency ("OCC") in Consent Order No. OCC-2025-003 (the "Consent Order"), which became effective on January 15, 2025. This Workstream 1 plan is one of five workstreams comprisin

II. Background and Regulatory Context A. Consent Order Findings Related to OFAC Sanctions Screening On January 15, 2025, the OCC issued Consent Order No. OCC-2025-003 against Belmont Ridge Bank National Association. The Consent Order identified multiple categories of BSA/AML compliance deficiencies, among which inadequate OFAC sanctions screening protocols for fintech BaaS transaction flows was identified as a core d

III. Root Cause Analysis Calderwood & Harkness, in conjunction with BRB's BSA Officer Thomas Ikeda, Chief Compliance Officer Patricia Langston, and CIO/CTO Linda Petrosian, and informed by the preliminary findings of Thornfield Consulting Group LLC's on-site assessment, has conducted a comprehensive root cause analysis of the OFAC screening deficiencies identified in the Consent Order. The root causes fall into four

IV. Remediation Objectives Based on the Consent Order requirements, the root cause analysis set forth in Section III above, and the consultative input of Thornfield Consulting Group LLC's on-site assessment team, Calderwood & Harkness and BRB management have defined the following eight (8) remediation objectives for Workstream 1. These objectives are designed to comprehensively address each identified deficiency and

V. Remediation Action Items and Implementation Plan This Section V sets forth the specific remediation action items and implementation steps that BRB will undertake to achieve the eight remediation objectives identified in Section IV. The action items are organized into five categories: (A) Technology Upgrade; (B) BaaS Channel Integration Requirements; (C) Policy and Procedure Revisions; (D) Staffing and Organization