CONFIDENTIAL — PREPARED FOR SUBMISSION TO THE OFFICE OF THE COMPTROLLER OF THE CURRENCY PURSUANT TO CONSENT ORDER NO. OCC-2025-003
INTERIM STATUS REPORT ON SUSPICIOUS ACTIVITY REPORT BACKLOG CLEARANCE
Prepared by: Calderwood & Harkness LLP Regulatory Counsel to Belmont Ridge Bank National Association 1285 Avenue of the Americas, 40th Floor New York, NY 10019
Submitted by: Belmont Ridge Bank National Association OCC Charter No. 48271 | FDIC Certificate No. 31845 680 Lexington Avenue, 22nd Floor New York, NY 10022
Submitted to: Office of the Comptroller of the Currency Northeastern District Office 340 Madison Avenue New York, NY 10017
Attn: Jonathan Frey, National Bank Examiner / Examiner-in-Charge
Reference: Consent Order No. OCC-2025-003, dated January 15, 2025 Article V — Requirement for Interim SAR Backlog Status Report Due March 31, 2025
Date of Report: March 31, 2025 C&H Matter No.: 1045-00002
Privilege Designation: This report is prepared for submission to the Office of the Comptroller of the Currency ("OCC") pursuant to Consent Order No. OCC-2025-003. While this report itself is submitted to the OCC in satisfaction of the Bank's interim reporting obligations, certain underlying analyses, memoranda, and work product of Calderwood & Harkness LLP prepared in connection with the matters described herein remain subject to attorney-client privilege and work-product protection, the disclosure of which is not intended and is not hereby waived. Nothing in this report shall be construed as a waiver of any applicable privilege or protection.
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I. EXECUTIVE SUMMARY
Belmont Ridge Bank National Association ("BRB" or the "Bank") respectfully submits this Interim Status Report on Suspicious Activity Report Backlog Clearance (this "Report") to the Office of the Comptroller of the Currency ("OCC") in compliance with the March 31, 2025 interim reporting deadline established under Article V of Consent Order No. OCC-2025-003 (the "Consent Order"). The purpose of this Report is to inform the OCC of BRB's progress toward the review, disposition, and clearance of the backlog of approximately 2,400 unreviewed suspicious activity monitoring alerts (the "Backlog" or the "Backlog Alerts") identified as of the conclusion of the OCC's targeted Bank Secrecy Act/Anti-Money Laundering ("BSA/AML") examination in September 2024.
Since the Consent Order's effective date of January 15, 2025, and since the formal engagement of Calderwood & Harkness LLP ("C&H") as outside regulatory counsel on February 10, 2025, BRB has mobilized significant internal and external resources to address the SAR backlog deficiency with the urgency and rigor commensurate with the seriousness of the OCC's findings. The Bank has made substantial progress toward clearing the Backlog and is on track to meet the June 30, 2025 full clearance target established in the Consent Order.
As of the date of this Report, BRB's progress is summarized as follows:
•  Total alerts in Backlog universe: 2,400
•  Alerts fully dispositioned (review complete, final determination made): 1,056 (44.0% of total Backlog)
•  Alerts resulting in SAR filings to date: 187 SARs filed with the Financial Crimes Enforcement Network ("FinCEN")
•  Alerts closed with no SAR required (documented rationale on file): 869 (82.3% of dispositioned alerts)
•  Alerts currently in active review / investigation: 624 (26.0% of total Backlog)
•  Alerts not yet assigned or commenced: 720 (30.0% of total Backlog)
•  Weekly average disposition rate (since full staffing deployment in mid-March 2025): approximately 176 alerts per week
BRB's target remains the full clearance of all 2,400 Backlog Alerts by June 30, 2025, with all resulting Suspicious Activity Reports ("SARs") filed or in final quality assurance review by that date. Based on the current weekly disposition rate and the resources deployed, BRB believes this target is achievable, subject to the risk factors identified in Section VIII of this Report.
BRB's BSA Officer, Thomas Ikeda, and Chief Compliance Officer, Patricia Langston, are jointly accountable for the execution of the backlog clearance workplan and for ensuring that the Bank's remediation efforts meet the standards and timelines established by the Consent Order. The remediation effort is being supported by 30 full-time-equivalent ("FTE") temporary compliance analysts provided by Pinnacle Compliance Solutions LLC ("Pinnacle") under a Managed Services Agreement, working under the oversight and supervision of BRB's permanent BSA/AML staff of 62 FTEs. Pinnacle analysts achieved full operational deployment by mid-March 2025 following the completion of onboarding, background checks, and BRB-specific training requirements.
In parallel with the Backlog clearance effort, BRB is addressing systemic process improvements designed to prevent the recurrence of SAR filing backlogs and to reduce the Bank's average SAR filing time from 78 days (as identified in the OCC examination) to within 30 days of alert disposition. These improvements include the adoption of a risk-based triage protocol, enhanced quality assurance standards, real-time alert-aging dashboards, and plans for the upgrade of BRB's transaction monitoring system to Veridian TMS v.10.0, with user acceptance testing targeted for completion by August 1, 2025.
BRB is committed to the full and timely remediation of all deficiencies identified in the Consent Order and appreciates the OCC's continued engagement and oversight in connection with these efforts.
II. BACKGROUND
A. Consent Order Context
On January 15, 2025, the OCC issued Consent Order No. OCC-2025-003 against Belmont Ridge Bank National Association, a national banking association organized under the laws of the United States, with its principal office located at 680 Lexington Avenue, 22nd Floor, New York, NY 10022. The Consent Order was the product of the OCC's targeted BSA/AML examination of BRB, which was conducted from March 2024 through September 2024, and which identified significant deficiencies in BRB's BSA/AML compliance program.
The Consent Order cited five core deficiency categories requiring comprehensive remediation:
(i) Inadequate OFAC Sanctions Screening: The OCC found that BRB's sanctions screening processes were not adequately designed or implemented to screen all relevant transactions and customer relationships, particularly within the Bank's Banking-as-a-Service ("BaaS") partnership channels, against the Office of Foreign Assets Control ("OFAC") Specially Designated Nationals and blocked Persons List and other applicable sanctions lists;
(ii) SAR Filing Deficiencies: The OCC identified the Backlog of approximately 2,400 unreviewed suspicious activity monitoring alerts and found that BRB's average SAR filing time of 78 days from alert generation significantly exceeded the regulatory expectation of timely filing, typically within 30 days;
(iii) Customer Due Diligence / Enhanced Due Diligence ("CDD/EDD") Failures: The OCC identified approximately 47,000 high-risk customer accounts for which BRB had failed to conduct or adequately document CDD and EDD procedures, in contravention of the requirements of 31 C.F.R. § 1020.210 and the OCC's implementing guidance;
(iv) Inadequate Model Validation for Veridian TMS v.8.3: The OCC found that the Bank's primary transaction monitoring system, Veridian TMS v.8.3, had not been subjected to independent model validation since March 2021, and that tuning parameters had last been updated in October 2022, raising concerns about the system's effectiveness in identifying potentially suspicious activity; and
(v) Board-Level Oversight Deficiencies: The OCC found that BSA/AML reporting to BRB's Board of Directors was only conducted on a quarterly basis and did not include key metrics such as SAR volumes, backlog status, filing timeliness, or SAR conversion rates, reflecting inadequate board-level oversight of the Bank's BSA/AML compliance program.
In connection with the Consent Order, BRB was assessed a civil money penalty ("CMP") of $14,500,000, payable within 60 days of the Consent Order's effective date (i.e., by March 16, 2025). BRB confirms that the CMP was paid in full to the United States Treasury on March 14, 2025, two days prior to the deadline.
BRB retained Calderwood & Harkness LLP on February 10, 2025 as outside regulatory counsel to advise and assist the Bank in connection with the comprehensive compliance-program uplift required by the Consent Order. C&H's engagement encompasses all five remediation workstreams, with particular focus on the SAR backlog clearance effort, the CDD/EDD remediation program, and the development of the Comprehensive Remediation Action Plan due to the OCC by May 15, 2025.
Thornfield Consulting Group LLC ("Thornfield") was engaged as the OCC-mandated independent consultant on February 10, 2025, following the OCC's non-objection to Thornfield's engagement, which was received on February 5, 2025. Thornfield's mandate includes the independent assessment of BRB's BSA/AML compliance program, review of the Bank's remediation efforts, and preparation of a final validation report, as further described in Section VI of this Report.
B. SAR Backlog Deficiency — Examination Findings
During the OCC's targeted BSA/AML examination conducted from March 2024 through September 2024, OCC examiners identified a backlog of approximately 2,400 potentially suspicious activity alerts that had been generated by BRB's transaction monitoring system but had not been reviewed, investigated, or dispositioned as of the examination conclusion date in September 2024. These alerts remained in an open, unassigned, or pending status within the Veridian TMS v.8.3 alert management queue, representing a material failure in BRB's obligation to timely identify, investigate, and report known or suspected violations of law or suspicious transactions, as required by 31 U.S.C. § 5318(g) and 12 C.F.R. § 21.11.
The OCC's examination findings further documented that BRB's average SAR filing time — measured from the date of alert generation to the date of SAR filing with FinCEN — was 78 days. This filing timeframe significantly exceeded the regulatory expectation of timely filing, which, consistent with FinCEN guidance and OCC supervisory expectations, is generally understood to require the filing of initial SARs within 30 days after the initial detection of facts that may constitute a basis for filing a SAR (or within 60 days if no suspect is identified).
To contextualize the scope of BRB's SAR-related operations, the Bank filed 3,847 SARs in calendar year 2024 and 2,914 SARs in calendar year 2023, reflecting a year-over-year increase of approximately 32.0%. The Veridian TMS v.8.3 transaction monitoring system generated 41,500 alerts in calendar year 2024, yielding a SAR conversion rate of approximately 9.3% (3,847 SARs filed ÷ 41,500 alerts generated). This conversion rate, while within certain industry benchmarks, warrants further analysis given the concerns identified by the OCC regarding potential over-alerting in some transaction monitoring scenarios and under-alerting in others.
Notably, BaaS-related SARs accounted for 2,108 of the 3,847 total SARs filed in calendar year 2024, representing approximately 54.8% of all SAR filings. This concentration reflects the significant suspicious activity risk present in BRB's fintech partnership channels and is consistent with the broader finding that BaaS transaction volumes have grown rapidly, reaching $74.3 billion in calendar year 2024 across 14 active fintech partners, and outpacing the Bank's investment in BSA/AML infrastructure to monitor such activity.
The SAR backlog deficiency identified in the September 2024 examination did not emerge in isolation. Rather, it represented an escalation from prior supervisory actions that had signaled the OCC's increasing concern with BRB's BSA/AML compliance posture. Specifically:
•  In June 2022, the OCC issued a Matter Requiring Attention ("MRA") regarding BSA/AML transaction monitoring, which identified weaknesses in BRB's alert review and disposition processes and recommended that the Bank enhance its staffing levels and workflow procedures to ensure timely review of all alerts generated by the transaction monitoring system.
•  In November 2023, the OCC escalated its supervisory concern by issuing a Matter Requiring Immediate Attention ("MRIA") regarding OFAC screening gaps, which identified systemic failures in the Bank's sanctions screening coverage, particularly for transactions processed through BaaS partner channels. The MRIA underscored the urgency of remediation and placed BRB on notice that failure to achieve satisfactory progress could result in formal enforcement action.
The progression from MRA to MRIA to the Consent Order reflects, in the OCC's view, BRB's inadequate remediation of prior supervisory actions and underscores the critical importance of the Bank's current remediation efforts.
Additionally, BRB's independent BSA/AML audit, conducted by Caldera & Pope LLP and completed in September 2024, identified multiple deficiencies that echoed the OCC's examination findings regarding SAR filing timeliness, alert disposition backlogs, and inadequate quality assurance procedures. The Caldera & Pope audit report was provided to the OCC's examination team during the course of the examination and informed certain aspects of the Consent Order.
C. Root Cause Analysis Summary
BRB, with the assistance of Calderwood & Harkness LLP and Thornfield Consulting Group LLC, has conducted a preliminary root cause analysis of the factors contributing to the SAR backlog deficiency. While the root cause analysis is ongoing and will be further refined as part of the Comprehensive Remediation Action Plan, the following principal contributing factors have been identified:
Insufficient Staffing. BRB's BSA/AML department, comprising 62 FTEs as of the date of the OCC examination, was inadequate to process the volume of alerts generated by the Veridian TMS v.8.3 system within required timeframes. The Bank's transaction monitoring system generated 41,500 alerts in calendar year 2024, requiring an average of approximately 798 alert reviews per week. With 62 FTEs allocated across all BSA/AML functions — including not only alert review and SAR filing but also CDD/EDD, OFAC screening, regulatory reporting, training, and supervision — the effective capacity dedicated to alert review and SAR investigation was insufficient to keep pace with alert generation volumes. This staffing shortfall was exacerbated by the rapid growth of BaaS transaction volumes, which reached $74.3 billion in calendar year 2024, distributed across 14 active fintech partners, and which generated a disproportionate share of complex, investigation-intensive alerts.
Transaction Monitoring Model Deficiencies. BRB's primary transaction monitoring system, Veridian TMS v.8.3, had not been subjected to independent model validation since March 2021, and tuning parameters for the system's alert generation rules and scenarios were last updated in October 2022. As a result, the system's alert generation logic did not adequately account for changes in BRB's business profile, including the significant expansion of BaaS activities, and was not calibrated to the Bank's current risk environment. The resulting alert output exhibited characteristics of both over-alerting (generating a high volume of alerts with a relatively low SAR conversion rate of 9.3%) and potential under-alerting (insufficient coverage of certain emerging typologies and transaction patterns). The high volume of alerts contributed directly to the Backlog by overwhelming the Bank's available review capacity.
BaaS Channel Complexity. BRB's 14 active fintech BaaS partners generated high volumes of complex transactions that required specialized investigation knowledge and more time-intensive alert review procedures. The three largest BaaS partners by transaction volume were:
•  NovaPay Technologies Inc. (Ethan Garrison, CEO): Approximately $30.5 billion in transaction volume in calendar year 2024, representing approximately 41% of total BaaS transaction volume. NovaPay's business model involves a high-volume digital payments platform serving small and medium-sized enterprises, with transaction patterns that frequently triggered structuring, rapid movement of funds, and third-party payment processor alerts.
•  FairLend Digital LLC (Aisha Okonkwo, CEO): Approximately $20.8 billion in transaction volume in calendar year 2024, representing approximately 28% of total BaaS transaction volume. FairLend operates a consumer lending platform with associated deposit and payment functionalities that generated alerts related to unusual fund flows and potential loan stacking patterns.
•  VaultEdge Inc. (Marcus Tan, CEO): Approximately $13.4 billion in transaction volume in calendar year 2024, representing approximately 18% of total BaaS transaction volume. VaultEdge provides digital asset custody and conversion services that generated alerts associated with high-risk geography flows and rapid movement of funds.
The complexity of investigating alerts arising from these BaaS channels — which often involved multi-layered payment chains, nested relationships, and unfamiliar transaction typologies — significantly increased the average time required to investigate and disposition each alert relative to alerts arising from BRB's traditional banking channels.
Inadequate Escalation and Prioritization Procedures. Prior to the implementation of the SAR Backlog Triage Protocol described in Section III.B of this Report, BRB's alert review processes employed a first-in-first-out ("FIFO") processing methodology that did not account for risk severity, alert type, customer risk rating, or other risk-based factors. As a result, high-risk alerts involving potential sanctions nexus, large-dollar transactions, or known high-risk jurisdictions were not prioritized for expedited review, while lower-risk or more routine alerts consumed review capacity. This approach was inconsistent with regulatory expectations for risk-based allocation of compliance resources and contributed to the accumulation of higher-risk alerts within the Backlog.
Governance Gaps. BSA/AML reporting to the Board of Directors of Belmont Ridge Financial Group, Inc. (the Bank's parent holding company) and the Board of BRB was conducted only on a quarterly basis and did not include key performance metrics such as SAR filing volumes, alert backlog status, filing timeliness trends, SAR conversion rates, or staffing adequacy assessments. The absence of timely and granular reporting to the Board impaired the Board's ability to identify and escalate the growing SAR backlog as a material compliance risk and to direct appropriate corrective action. This governance gap has been partially addressed through the establishment of a dedicated Compliance Committee of the Board, chaired by James Rutherford, as further described in Section X of this Report.
III. SAR BACKLOG CLEARANCE — SCOPE AND METHODOLOGY
A. Backlog Definition
The universe of alerts subject to the SAR backlog clearance effort (the "Backlog" or "Backlog Alerts") consists of 2,400 transaction monitoring alerts generated by BRB's Veridian TMS v.8.3 system that were identified by the OCC as unreviewed or undispositioned as of the conclusion of the OCC's targeted BSA/AML examination in September 2024. For purposes of this Report and the backlog clearance workplan, an alert is classified as "unreviewed or undispositioned" if, as of September 2024, it remained in an open, pending, or unassigned status within the Veridian TMS v.8.3 alert management queue and had not been the subject of a documented investigation, review, and final disposition determination.
The Backlog Alerts encompass alerts generated across all transaction monitoring scenarios configured within the Veridian TMS v.8.3 system, including but not limited to:
•  Structuring and structuring-related activity;
•  Rapid movement of funds;
•  Unusual wire transfer activity (domestic and international);
•  High-risk geography indicators;
•  High-risk customer segment activity;
•  BaaS partner-specific monitoring scenarios;
•  Unusual cash activity;
•  Third-party payment processor activity;
•  Peer-based anomaly detection; and
•  ACH and electronic funds transfer anomalies.
The Backlog Alerts span all of BRB's business channels, including retail banking, commercial lending, wealth management, and BaaS/fintech partnership channels. The time period during which these alerts were generated extends across the period leading up to the September 2024 examination conclusion, with the majority of Backlog Alerts having been generated between January 2024 and September 2024, though a limited number date back to the latter portion of calendar year 2023.
It is important to note that the 2,400-alert Backlog represents a discrete population of alerts identified as of the examination conclusion date. This Backlog clearance effort is distinct from, though related to, the broader SAR lookback project described in Section IV.C below, which covers a defined historical review period and encompasses transaction types and customer populations beyond the discrete Backlog universe.
B. Triage and Prioritization Framework
Following the issuance of the Consent Order and the engagement of Calderwood & Harkness LLP, BRB implemented a risk-based triage protocol (the "SAR Backlog Triage Protocol" or the "Triage Protocol") to replace the prior FIFO processing methodology and to ensure that the highest-risk alerts within the Backlog are reviewed and dispositioned first. The Triage Protocol was developed in coordination between BRB's BSA/AML team and Calderwood & Harkness LLP and was finalized on February 24, 2025.
The Triage Protocol employs a multi-factor risk-ranking methodology to assign each Backlog Alert to one of three triage tiers. The risk-ranking criteria used for prioritization include:
•  Transaction amount and volume: Alerts involving individual transactions above $100,000 or cumulative transaction activity above $500,000 within a rolling 30-day period are assigned higher risk scores.
•  Customer risk rating: Alerts involving customers with high-risk CDD/EDD classifications, including politically exposed persons ("PEPs"), money services businesses ("MSBs"), and customers in high-risk industry segments, are prioritized.
•  Alert type and monitoring scenario: Alerts generated by scenarios associated with higher-risk typologies (e.g., structuring, rapid movement of funds, high-risk geography) receive higher priority than alerts generated by lower-risk or anomaly-based scenarios.
•  BaaS partner association: Alerts related to transactions originating through NovaPay Technologies Inc., FairLend Digital LLC, and VaultEdge Inc. are assigned elevated priority, given the concentration of suspicious activity risk in these channels and the complexity of the associated transaction flows.
•  Geographic risk indicators: Alerts involving transactions with nexus to jurisdictions identified as high-risk by the Financial Action Task Force ("FATF"), FinCEN advisory notices, or BRB's internal country risk rating system are prioritized.
•  Relationship to prior SAR filings: Alerts involving customers or accounts for which BRB has previously filed SARs, or which are the subject of existing continuing activity SAR monitoring, are elevated in priority to ensure continuity of suspicious activity reporting.
Based on the application of these criteria, each Backlog Alert has been assigned to one of the following triage tiers:
•  Tier 1 (Highest Risk — Immediate Review): Alerts meeting multiple high-risk criteria, including those involving potential sanctions nexus, transactions exceeding specified dollar thresholds (individual transactions over $250,000 or aggregate activity over $1,000,000), known high-risk jurisdictions (FATF gray-listed or black-listed countries), or patterns consistent with significant money laundering or terrorist financing typologies. Tier 1 alerts are assigned for immediate review upon triage completion.
•  Tier 2 (Elevated Risk — Review Within 30 Days of Triage): Alerts meeting one or more elevated risk criteria, including BaaS-related alerts involving the three largest fintech partners, alerts with customer risk ratings of "high" or "medium-high," and alerts involving transaction types with higher historical SAR conversion rates. Tier 2 alerts are assigned for review within 30 calendar days of triage assignment.
•  Tier 3 (Standard Risk — Review Within 60 Days of Triage): Alerts that, based on the risk-ranking criteria, present standard risk characteristics and do not meet the elevated criteria for Tier 1 or Tier 2 classification. Tier 3 alerts are assigned for review within 60 calendar days of triage assignment.
The approximate distribution of the 2,400 Backlog Alerts across the three triage tiers is as follows:
In addition to the tier-based prioritization, the Triage Protocol establishes escalation thresholds for specific categories of alerts requiring heightened scrutiny. Alerts involving a potential sanctions nexus (including transactions involving OFAC-listed individuals, entities, or jurisdictions), transactions individually exceeding $500,000, or activity with connections to jurisdictions subject to comprehensive U.S. sanctions programs are automatically escalated to senior BRB investigators for review and are subject to direct oversight by BSA Officer Thomas Ikeda. Alerts presenting potential law enforcement interest or requiring coordination with BRB's OFAC compliance function are further escalated through documented protocols.
C. Review and Disposition Standards
Each Backlog Alert is subject to a structured, documented review process designed to ensure thoroughness, consistency, and compliance with regulatory expectations. The review process for each alert includes the following steps:
1.  Transaction Data Retrieval and Analysis: The assigned analyst retrieves and reviews the underlying transaction data that triggered the alert, including transaction amounts, dates, originator and beneficiary information, transaction descriptions, and relevant metadata from BRB's core banking system and the Veridian TMS v.8.3 platform.
2.  Customer Account Review: The analyst reviews the customer's account profile, transaction history, account opening documentation, and any prior alerts or SARs associated with the customer to establish context for the alert activity.
3.  CDD/EDD File Review: The analyst reviews the customer's CDD and, where applicable, EDD documentation to assess whether the alerted activity is consistent with the customer's known risk profile, expected account activity, source of funds, and source of wealth. Where CDD/EDD files are incomplete or outdated, the analyst documents the deficiency and coordinates with BRB's CDD/EDD remediation team to obtain supplemental information where feasible.
4.  Open-Source and Database Research: The analyst conducts open-source research and database searches (including adverse media screening, beneficial ownership databases, and sanctions screening tools) to identify any additional risk-relevant information concerning the customer or the transaction counterparties.
5.  Narrative Assessment: The analyst prepares a written narrative assessment documenting the alert details, the investigation conducted, the findings, and the analyst's recommended disposition.
6.  Disposition Recommendation: Based on the investigation, the analyst recommends one of the following disposition outcomes:
(a) SAR Filing Required: The investigation reveals sufficient indicia of known or suspected suspicious activity to warrant the filing of a SAR with FinCEN. The alert proceeds to the SAR drafting stage, followed by quality review by senior BRB compliance staff, and submission to FinCEN through the BSA E-Filing System.
(b) No SAR Required — Alert Closed: The investigation does not reveal sufficient indicia of suspicious activity to warrant SAR filing. The alert is closed with a documented rationale explaining the basis for the no-SAR determination, including a description of the investigation conducted, the information considered, and the reasons supporting the conclusion that the activity does not meet the SAR filing threshold.
(c) Additional Investigation Required: The initial review indicates that supplemental analysis is needed before a disposition determination can be made. The alert is returned to the investigation queue with documentation of the additional steps required (e.g., obtaining additional CDD/EDD documentation, conducting follow-up research, or requesting transaction detail from a BaaS partner).
All SAR narratives arising from the Backlog clearance effort are subject to a multi-level quality review process prior to filing with FinCEN. This process includes review by a senior BRB compliance analyst (Level 1 review), followed by review by a BRB BSA/AML manager or supervisor (Level 2 review), and, for Tier 1 alerts and other complex or high-risk matters, review and approval by BSA Officer Thomas Ikeda or his designee (Level 3 review). The quality review process is designed to ensure that SAR narratives are complete, accurate, and clearly articulate the suspicious activity identified, the parties involved, and the basis for the filing.
The filing timeliness target for SARs arising from the Backlog clearance effort is 30 calendar days from the date of the alert disposition decision (i.e., the date on which the analyst's recommendation of "SAR Filing Required" is approved through the quality review process). This target is consistent with the regulatory expectation of timely SAR filing and represents a significant improvement over the 78-day average filing time identified in the OCC examination.
IV. RESOURCE DEPLOYMENT
A. Pinnacle Compliance Solutions LLC — Temporary Staffing
To address the immediate staffing shortfall identified as a root cause of the SAR backlog deficiency, BRB engaged Pinnacle Compliance Solutions LLC ("Pinnacle") under a Managed Services Agreement (Statement of Work Reference: PCS-BRB-2025-0012, effective February 10, 2025) to provide 30 full-time-equivalent BSA/AML analysts for a 12-month engagement period. The total contract value for the Pinnacle engagement is $3,600,000, calculated as 30 FTEs at a rate of $10,000 per FTE per month over a 12-month period, resulting in a monthly cost of $300,000. The key contact at Pinnacle is Andrea Solis, Director of Managed Services, located at Pinnacle's offices at 90 Broad Street, 20th Floor, New York, NY 10004.
The staffing deployment timeline for the Pinnacle engagement proceeded as follows:
•  February 10, 2025: Managed Services Agreement executed; candidate identification and screening commenced.
•  February 17–28, 2025: Initial cohort of 18 Pinnacle analysts completed background checks, credentialing, and system access provisioning; onboarding and BRB-specific BSA/AML training commenced.
•  March 3, 2025: Initial cohort of 18 Pinnacle analysts commenced active alert review work on the Backlog.
•  March 10–14, 2025: Second cohort of 12 Pinnacle analysts completed onboarding and training.
•  March 17, 2025: Full 30-FTE complement deployed and operational, achieving the targeted staffing level for the backlog clearance effort.
The roles assigned to Pinnacle analysts are tailored to the needs of the Backlog clearance effort and include: SAR investigators responsible for conducting alert investigations and preparing disposition recommendations and SAR narratives; transaction monitoring alert reviewers responsible for the initial triage and Level 1 review of alerts; and KYC/CDD research analysts responsible for conducting customer research, open-source investigations, and CDD/EDD file review in support of alert dispositions.
All Pinnacle temporary staff are required to complete BRB-specific BSA/AML training before commencing alert reviews. The training program covers BRB's BSA/AML policies and procedures, the SAR Backlog Triage Protocol, the review and disposition standards described in Section III.C, the Bank's customer risk rating methodology, BaaS-specific investigation procedures, and the use of BRB's systems and tools, including the Veridian TMS v.8.3 platform. Training is delivered over a three-day period and includes both classroom instruction and supervised alert review exercises.
Pinnacle analysts report to and are supervised by BRB's permanent BSA/AML staff under the direction of BSA Officer Thomas Ikeda. Specifically, Pinnacle analysts are organized into teams of five, each supervised by a designated BRB BSA/AML manager who is responsible for work assignment, quality oversight, and escalation management. This supervisory structure ensures that all Backlog alert reviews conducted by Pinnacle analysts are subject to the same standards and quality expectations as reviews conducted by BRB's permanent staff.
B. BRB Internal Resources
BRB's existing BSA/AML department, comprising 62 FTEs, is contributing to the Backlog clearance effort in addition to maintaining the department's ongoing operational responsibilities. A dedicated internal team has been assigned to the following Backlog-related functions:
•  Backlog Triage Oversight: BRB's senior BSA/AML managers supervised the initial risk-based triage and tier assignment of all 2,400 Backlog Alerts, ensuring consistency in the application of the Triage Protocol.
•  Quality Review: BRB permanent staff perform all Level 2 and Level 3 quality reviews of alert disposition recommendations and SAR narratives prepared by Pinnacle analysts, ensuring that all dispositions and filings meet BRB's quality standards.
•  SAR Filing: BRB permanent staff are responsible for the final preparation and submission of SARs to FinCEN through the BSA E-Filing System, ensuring that all filing requirements are met.
•  Escalation Management: BRB senior investigators handle escalated matters, including Tier 1 alerts, alerts with potential sanctions nexus, and matters requiring coordination with law enforcement or BRB's OFAC compliance function.
In addition to the existing 62 FTEs, BRB is in the process of recruiting and hiring 15 additional permanent FTE positions within the BSA/AML department, which would increase the department's permanent headcount from 62 to 77 FTEs upon completion. These positions include senior BSA/AML investigators, transaction monitoring analysts, a dedicated BaaS compliance team lead, and additional SAR quality reviewers. The estimated fully loaded annual cost of these 15 positions is $2,250,000 (15 FTEs × $150,000 average fully loaded cost per FTE). As of the date of this Report, BRB has extended offers to eight candidates, with five having accepted and commenced employment; the remaining ten positions are in various stages of the recruitment process. BRB anticipates that all 15 positions will be filled by June 30, 2025.
Patricia Langston, Chief Compliance Officer, provides executive oversight of the Backlog clearance effort and reports on remediation progress to the Board of Directors and the newly established Compliance Committee on a monthly basis. Thomas Ikeda, BSA Officer and AML Program Director, provides day-to-day operational management of the Backlog clearance workplan, including staffing allocation, quality review oversight, and escalation management.
C. SAR Lookback Project
In addition to the 2,400-alert Backlog clearance effort, BRB has initiated a broader SAR lookback project (the "SAR Lookback Project") designed to assess whether additional suspicious activity may have gone unreported during a defined historical review period extending beyond the discrete Backlog universe. The SAR Lookback Project has an estimated total budget of $5,500,000 and is being managed as a separate but coordinated workstream within BRB's overall remediation program.
The SAR Lookback Project encompasses a review of transaction types, customer populations, and monitoring scenarios that are broader in scope than the 2,400 Backlog Alerts. The lookback review period, the specific customer populations and transaction types in scope, and the methodology for the lookback analysis have been defined in a separate memorandum prepared in coordination between BRB, Calderwood & Harkness LLP, and BRB's BSA/AML team. This memorandum will be subject to review by Thornfield Consulting Group LLC as part of the independent consultant's assessment of BRB's remediation methodology.
The SAR Lookback Project may result in additional SAR filings beyond those arising from the 2,400-alert Backlog clearance effort. Any additional SARs identified through the lookback process will be filed with FinCEN in accordance with the same timeliness and quality standards applicable to the Backlog SARs. BRB will report on the progress and findings of the SAR Lookback Project in subsequent reports to the OCC, including in the Comprehensive Remediation Action Plan due May 15, 2025 and in the first quarterly progress report due September 15, 2025.
D. Quality Control Protocols
Calderwood & Harkness LLP, in coordination with BRB's BSA/AML leadership, has developed and implemented comprehensive quality control ("QC") protocols applicable to the Backlog clearance effort. These protocols are designed to ensure the accuracy, completeness, and consistency of alert reviews, disposition determinations, and SAR filings, and to provide a defensible record of the Bank's remediation work.
The QC protocols include the following key elements:
•  Supervisory Review Sampling Rates: All Pinnacle analyst work product is subject to supervisory review by BRB permanent staff. During the initial ramp-up period (the first 30 days of each analyst's deployment), 100% of all alert dispositions are subject to Level 2 supervisory review. Following the initial ramp-up period, the supervisory review sampling rate is set at no less than 25% for Tier 2 and Tier 3 alerts, while 100% supervisory review is maintained for all Tier 1 alert dispositions.
•  Alert Disposition Accuracy Benchmarks: BRB has established target accuracy benchmarks for alert dispositions, defined as the percentage of dispositions that are affirmed without material modification upon supervisory review. The target accuracy rate is 95%. Analysts whose accuracy rates fall below 90% are subject to additional training and increased supervisory review sampling until performance improves.
•  SAR Narrative Quality Standards: SAR narratives must meet documented quality standards, including a clear description of the suspicious activity, identification of all relevant parties and accounts, specification of the relevant timeframe and transaction amounts, and a complete explanation of why the activity is suspicious. SAR narratives are evaluated against a standardized quality checklist during the quality review process.
•  Escalation Procedures: Documented escalation procedures govern the handling of complex, high-risk, or unusual matters encountered during the Backlog review, including matters involving potential sanctions nexus, law enforcement interest, or systemic patterns of suspicious activity.
A dedicated Quality Assurance ("QA") team within BRB, consisting of four experienced BSA/AML professionals, reviews a statistically significant random sample of all alert dispositions (targeting a 95% confidence level with a 5% margin of error) plus a targeted risk-based sample focusing on Tier 1 dispositions, no-SAR determinations for alerts with high risk scores, and dispositions involving BaaS-related alerts. QA findings are tracked, reported to BSA Officer Thomas Ikeda on a weekly basis, and used to identify training needs, process improvements, and any systemic issues requiring corrective action.
V. PROGRESS TO DATE (AS OF MARCH 31, 2025)
A. Quantitative Progress
As of March 31, 2025, BRB has made the following quantitative progress toward clearance of the 2,400-alert Backlog:
Since the full deployment of the 30-FTE Pinnacle analyst team on March 17, 2025, BRB has achieved a weekly average disposition rate of approximately 176 alerts per week. This rate represents a significant increase from the pre-deployment rate and reflects the combined capacity of the Pinnacle analysts and BRB's permanent staff. During the initial ramp-up period prior to full Pinnacle deployment (approximately February 24 through March 14, 2025), the disposition rate was lower as BRB's permanent staff conducted alert reviews while Pinnacle analysts were undergoing onboarding and training.
The SAR conversion rate for the Backlog population (187 SARs filed out of 1,056 dispositioned alerts, or 17.7%) is notably higher than the Bank's overall SAR conversion rate of 9.3% for calendar year 2024 alerts. This elevated conversion rate is consistent with expectations, given that the Backlog represents an accumulation of alerts that remained undispositioned — including a disproportionate number of higher-risk and more complex alerts that required longer investigation times — and given that the risk-based triage protocol has prioritized higher-risk alerts for initial review.
B. Breakdown by Triage Tier
The following table presents the Backlog clearance progress broken down by triage tier as of March 31, 2025:
As reflected in the table above, the risk-based triage approach has resulted in the prioritization and near-completion of Tier 1 alert reviews. Of the 384 Tier 1 alerts, 312 (81.3%) have been fully dispositioned, with the remaining 72 in active review or pending final assignment. BRB expects to complete all Tier 1 dispositions by April 30, 2025.
Tier 2 alerts are progressing on schedule, with 528 of 816 (64.7%) dispositioned as of the report date. The remaining 288 Tier 2 alerts are either in active review or pending assignment and are on track for completion by May 31, 2025.
Tier 3 alerts, which represent the largest tier by volume (1,200 alerts, 50.0% of the total Backlog) but the lowest risk profile, have been addressed to a lesser degree to date, with 216 of 1,200 (18.0%) dispositioned. This is consistent with the Triage Protocol's design, which directs resources first to higher-risk alerts. Tier 3 alerts will constitute the bulk of the remaining work through June 2025 and will be the primary focus of the Pinnacle and BRB review teams once Tier 1 and Tier 2 dispositions are substantially completed.
The SAR conversion rate varies by tier, as expected: Tier 1 alerts have yielded a SAR conversion rate of 28.5% (89 SARs from 312 dispositions), reflecting the higher-risk profile of these alerts; Tier 2 alerts have yielded a conversion rate of 15.5% (82 SARs from 528 dispositions); and Tier 3 alerts have yielded a conversion rate of 7.4% (16 SARs from 216 dispositions) to date.
C. Breakdown by Channel
The following table presents the Backlog clearance progress broken down by business channel as of March 31, 2025:
BaaS/fintech partnership-related alerts represent the largest category within the Backlog, totaling 1,344 alerts or 56.0% of the total Backlog. This is consistent with the overall finding that BaaS-related SARs constitute approximately 54.8% of BRB's total SAR filings and reflects the concentration of suspicious activity risk in the fintech partnership channels. Of the 576 BaaS-related alerts dispositioned to date, 118 (20.5%) have resulted in SAR filings, representing the highest SAR conversion rate of any channel within the Backlog.
Within the BaaS/fintech partnership channel, the Backlog alerts are attributable to BRB's fintech partners as follows:
•  NovaPay Technologies Inc. (Ethan Garrison, CEO): Approximately 552 Backlog Alerts (41.1% of BaaS-related alerts), of which approximately 228 have been dispositioned, resulting in 54 SAR filings.
•  FairLend Digital LLC (Aisha Okonkwo, CEO): Approximately 376 Backlog Alerts (28.0% of BaaS-related alerts), of which approximately 168 have been dispositioned, resulting in 35 SAR filings.
•  VaultEdge Inc. (Marcus Tan, CEO): Approximately 242 Backlog Alerts (18.0% of BaaS-related alerts), of which approximately 108 have been dispositioned, resulting in 22 SAR filings.
•  Other BaaS partners (11 partners): Approximately 174 Backlog Alerts (12.9% of BaaS-related alerts), of which approximately 72 have been dispositioned, resulting in 7 SAR filings.
Retail banking alerts represent 528 alerts (22.0% of the total Backlog) and have the highest disposition rate by channel (50.0%), reflecting the generally lower complexity of retail banking alert investigations. Commercial lending alerts (336 alerts, 14.0%) have a lower disposition rate (39.3%), reflecting the more document-intensive investigation requirements associated with commercial account activity. Wealth management alerts (192 alerts, 8.0%) represent the smallest channel-specific category and have been dispositioned at a rate of 43.8%.
D. Preliminary Findings
While the Backlog clearance effort is ongoing and a comprehensive analysis of findings will be provided in the broader SAR Lookback Project report and shared with Thornfield Consulting Group LLC, BRB has identified the following preliminary observations regarding the nature and patterns of suspicious activity within the Backlog:
Structuring Patterns. A significant number of Backlog Alerts involve potential structuring activity, including patterns of cash deposits, electronic transfers, or other transactions conducted in amounts designed to evade the $10,000 Currency Transaction Report ("CTR") threshold. Structuring-related alerts are present across all channels but are particularly prevalent in the retail banking and BaaS channels, where transaction volumes and fragmentation provide greater opportunity for structured activity.
Rapid Movement of Funds. Numerous alerts involve rapid movement of funds patterns, in which deposits are received and then quickly transferred or withdrawn, often within 24 to 48 hours, with minimal apparent business purpose. These patterns are especially common in alerts associated with NovaPay Technologies Inc.'s merchant payment platform, where funds flow through BRB-held accounts with high velocity.
Third-Party Payment Processor Activity. Backlog Alerts associated with BaaS partner channels include a notable cluster of alerts related to potential third-party payment processor ("TPPP") abuse, in which BRB-held accounts appear to have been used to process payments on behalf of undisclosed or inadequately identified third parties. These alerts raise concerns regarding BRB's visibility into the end-users and beneficial owners of accounts maintained through its BaaS partners.
High-Risk Jurisdiction Flows. A subset of Backlog Alerts involves international wire transfers to or from jurisdictions identified as high-risk, including jurisdictions subject to FATF advisories or U.S. government geographic targeting orders. Alerts in this category have been prioritized under the Triage Protocol and have yielded a higher-than-average SAR conversion rate.
Systemic Observations. The review has identified certain patterns suggesting systemic weaknesses in BRB's transaction monitoring scenarios and BaaS partner oversight. Specifically, the review team has observed: (i) instances in which the Veridian TMS v.8.3 system generated alerts based on scenarios that were not adequately calibrated to the transaction patterns of specific BaaS partners, resulting in both missed suspicious activity and a high volume of alerts that, upon investigation, did not warrant SAR filing; (ii) gaps in the information provided by certain BaaS partners to BRB regarding end-customer identity and transaction purpose, which complicate alert investigations and may indicate deficiencies in the partners' own compliance controls; and (iii) patterns of repeat suspicious activity involving certain customer accounts that suggest the need for enhanced ongoing monitoring and, in some cases, account termination or restriction.
Escalated Matters. To date, the Backlog review has identified 14 matters that required escalation to senior management and/or the BSA Officer beyond the standard alert review and SAR filing process. These escalated matters include three cases involving potential OFAC sanctions implications that were referred to BRB's OFAC compliance function for additional screening and review, and two cases in which the nature and severity of the identified suspicious activity warranted consideration of a voluntary law enforcement referral. All escalated matters are being tracked and documented, and their disposition will be reported to Thornfield Consulting Group LLC as part of the independent consultant's assessment.
Detailed findings from the Backlog clearance effort are being compiled for inclusion in the comprehensive SAR Lookback Project report and will be shared with Thornfield Consulting Group LLC to inform the independent consultant's assessment of BRB's BSA/AML compliance program and remediation progress.
E. SAR Filing Timeliness — Current Performance
A key objective of the Backlog clearance effort is to demonstrate BRB's ability to achieve and sustain SAR filing timeliness in compliance with regulatory expectations. For SARs generated from the Backlog clearance effort, BRB reports the following timeliness performance:
•  Average filing time from disposition decision to FinCEN filing: For the 187 SARs filed to date from the Backlog clearance effort, the average time from the date of the alert disposition decision (i.e., the date on which the "SAR Filing Required" determination was approved through the quality review process) to the date of FinCEN filing is 18 days.
•  Comparison to examination baseline: This represents a significant improvement from the 78-day average filing time identified during the OCC's examination, which measured the period from alert generation to SAR filing. The 18-day figure measures a different, narrower interval (disposition decision to filing), but it demonstrates that BRB's post-disposition SAR preparation and filing workflow is operating well within the 30-day target.
•  End-to-end metric: When measured from the date of alert assignment (i.e., the date on which the alert was assigned to an analyst for investigation as part of the Backlog clearance effort) to the date of FinCEN filing, the average for the 187 SARs filed to date is approximately 34 days. While this exceeds the 30-day target by a modest margin, this figure reflects the investigation time required for alerts that had been languishing in the Backlog for months and, in many cases, required more extensive research than would typically be needed for a newly generated alert. BRB anticipates that this end-to-end metric will improve as the review team gains efficiency and as lower-complexity Tier 3 alerts constitute a larger share of the remaining dispositions.
Process improvements implemented to date to accelerate SAR filing timeliness include:
•  New workflow design: BRB has redesigned its SAR preparation workflow to reduce handoff delays between the investigation, narrative drafting, quality review, and filing stages. The new workflow establishes specific service-level targets for each stage and utilizes an automated task-routing system within the Veridian TMS platform to track progress and flag approaching deadlines.
•  Queue management: BSA Officer Thomas Ikeda conducts daily queue management reviews to identify bottlenecks, reassign capacity as needed, and ensure that alerts approaching filing timeliness targets are prioritized.
•  QA streamlining: The quality review process has been streamlined to reduce turnaround time without sacrificing review rigor, including the implementation of pre-populated SAR narrative templates, standardized quality checklists, and parallel (rather than sequential) review by multiple reviewers for Tier 2 and Tier 3 SARs.
VI. COORDINATION WITH INDEPENDENT CONSULTANT
Thornfield Consulting Group LLC ("Thornfield"), engaged as the OCC-mandated independent consultant under Engagement Reference TCG-BRB-2025-001, commenced its on-site assessment on March 1, 2025. Thornfield's engagement team is led by Dr. Vivian Castellano, Managing Director, Financial Crimes Advisory, and includes the following senior team members:
•  Robert Eastman, Senior Director, AML Transaction Monitoring, who is leading Thornfield's assessment of BRB's transaction monitoring program, including the Veridian TMS v.8.3 configuration, alert management processes, and the SAR backlog clearance methodology;
•  Jennifer Hwang, Director, Sanctions & OFAC Compliance, who is leading Thornfield's assessment of BRB's OFAC screening program and the remediation of sanctions screening deficiencies;
•  Nathaniel Burgess, Director, Fintech & Payments Compliance, who is leading Thornfield's assessment of BRB's BaaS/fintech partnership compliance framework and the associated risks identified in the Consent Order.
Thornfield has been provided with full access to BRB's SAR backlog clearance workplan, the SAR Backlog Triage Protocol, individual alert disposition files and work papers, SAR narratives, quality control results and QA reports, staffing deployment records, and other documentation relevant to the Backlog clearance effort, pursuant to the Access & Cooperation Protocol agreed between BRB, Calderwood & Harkness LLP, and Thornfield on February 14, 2025. BRB has designated a dedicated liaison within the BSA/AML department to coordinate information requests and facilitate Thornfield's access to personnel and systems.
Thornfield's preliminary gap assessment is due April 15, 2025, as established in the Consent Order. BRB anticipates that the preliminary gap assessment will include observations and recommendations regarding the SAR backlog clearance methodology, the adequacy of the Triage Protocol, the quality and consistency of alert disposition determinations and SAR narratives, and the sufficiency of staffing and resources allocated to the effort. BRB is prepared to incorporate Thornfield's recommendations into its backlog clearance approach and to make adjustments to the methodology, staffing, or timeline as warranted.
BRB and Calderwood & Harkness LLP maintain regular bi-weekly status calls with Thornfield, held on alternating Tuesdays, to provide updates on Backlog clearance progress, discuss emerging issues, respond to Thornfield's inquiries, and ensure alignment and transparency between BRB's remediation team and the independent consultant. The most recent bi-weekly call was held on March 25, 2025, during which BRB provided Thornfield with a preliminary version of the quantitative progress data presented in Section V of this Report.
Thornfield's observations and recommendations will inform any necessary adjustments to the Backlog clearance approach. BRB commits to promptly communicating to the OCC any material concerns raised by Thornfield regarding the adequacy or pace of the Backlog clearance effort.
VII. COORDINATION WITH FINCEN
The Financial Crimes Enforcement Network ("FinCEN") is monitoring BRB's SAR filing remediation in coordination with the OCC. As of the date of this Report, FinCEN has not filed a separate enforcement action against BRB, although FinCEN has reserved its enforcement rights in connection with the BSA/AML deficiencies identified in the OCC examination. BRB understands that FinCEN's decision regarding the exercise of its enforcement authority may be informed, in part, by BRB's progress in remediating the SAR backlog and broader BSA/AML compliance deficiencies and by the Bank's cooperation and good faith in the remediation process.
BRB's primary FinCEN liaison is Angela Drummond, Associate Director, Enforcement Division. BRB, through Calderwood & Harkness LLP, has been in periodic communication with Ms. Drummond's office to provide updates on the Bank's remediation progress and to respond to information requests.
BRB is committed to ensuring that all SARs filed as part of the Backlog clearance effort — as well as all SARs filed in the ordinary course of BRB's BSA/AML compliance operations — meet FinCEN's filing quality standards, including the completeness and accuracy of SAR form data and the quality and specificity of SAR narratives. BRB will continue to provide information to FinCEN as requested and will coordinate with the OCC on any FinCEN inquiries related to the Bank's SAR filing remediation efforts.
VIII. CHALLENGES AND RISK FACTORS
BRB has identified the following challenges and risk factors that have affected or may affect the pace, scope, or outcome of the SAR backlog clearance effort. BRB is actively managing these risks and will promptly communicate to the OCC if any of these factors materially jeopardizes the June 30, 2025 clearance deadline.
Staffing Ramp-Up Timing. Full deployment of the 30 Pinnacle FTEs required approximately four to six weeks from the date of engagement execution (February 10, 2025) due to the time required for candidate identification, background checks, system access provisioning, and BRB-specific BSA/AML training. The initial cohort of 18 analysts commenced active review on March 3, 2025, with the full 30-FTE complement not operational until March 17, 2025. This ramp-up period limited the alert disposition throughput during February and early March, contributing to a lower-than-projected cumulative disposition count as of the report date. However, the weekly disposition rate since full deployment (approximately 176 alerts per week) is on track to support timely completion of the Backlog by June 30, 2025, assuming sustained throughput.
Alert Complexity. A subset of Backlog Alerts, particularly those involving BaaS partner transaction flows and multi-layered payment chains, require substantially more investigation time than standard alerts. Alerts involving NovaPay Technologies Inc.'s merchant payment platform, for example, often require the analyst to trace transaction flows through multiple intermediary accounts, request additional transaction detail from the BaaS partner, and conduct enhanced open-source research on the underlying merchants and their beneficial owners. BRB estimates that the average investigation time for complex BaaS-related alerts is approximately 6–8 hours per alert, compared to approximately 2–3 hours for standard retail banking alerts. This complexity differential may affect the disposition rate for the remaining BaaS-related alerts in Tier 2 and Tier 3.
CDD/EDD Documentation Gaps. The Backlog clearance effort has identified instances in which alert investigations cannot be fully completed without adequate customer due diligence files. In certain cases, CDD and EDD documentation for the customer associated with a Backlog Alert is incomplete, outdated, or missing, reflecting the broader CDD/EDD deficiency identified by the OCC (approximately 47,000 high-risk accounts requiring remediation). Where CDD/EDD gaps are identified during a Backlog alert review, the alert is flagged and the investigation team coordinates with BRB's CDD/EDD remediation team to obtain supplemental documentation. This dependency on the concurrent CDD/EDD remediation project may create delays for a subset of Backlog Alerts, particularly those associated with high-risk customer accounts for which CDD/EDD remediation has not yet been completed. BRB is actively managing this dependency through cross-workstream coordination and prioritization of CDD/EDD remediation for customers with associated Backlog Alerts.
Transaction Monitoring System Limitations. The existing Veridian TMS v.8.3 system, which has not been independently validated since March 2021 and was last tuned in October 2022, continues to generate new transaction monitoring alerts during the Backlog clearance period. While these new alerts