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Extract to table / sub-processor-risk-allocation-memo.docx
sub-processor-risk-allocation-memo.docx
Parties
Harkness LLP
Skybridge Fintech Ltd
OCC Computer-Security Inc
Transaction Context Skybridge Fintech Ltd
Stoddard LLP
Ketchum LLP
Ironvault Security Group LLC
Dates
December 6, 2025
January 15, 2026
February 15, 2026
June 6, 2023
March 1, 2024
December 12, 2025
January 1, 2025
December 31, 2025
October 1, 2024
September 15, 2025
Amounts
$6.1
$2.74
$13.7
$5.0
$5.48
$10
$20
Obligations
Each sub-processor performs distinct but critical functions in the data processing chain, and each presents its own set of risk allocation considerations that must be addressed in the DPA
The sub-processor risk allocation framework must simultaneously satisfy several overlapping regulatory and contractual requirements
Second, the framework must comply with GDPR Article 28 requirements, which are triggered because approximately 3,200 of Meridian's accountholders are residents of EU Member States
Third, the framework must address applicable U
Regulatory and Legal Framework for Sub-Processor Oversight The sub-processor risk allocation framework must be structured to satisfy the requirements of multiple, overlapping regulatory regimes
Article 28(2) provides that a processor shall not engage another processor (i