FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / regulatory-compliance-memo.docx
regulatory-compliance-memo.docx · 1009-00007

Parties

HARKNESS LLP
Skybridge Fintech Ltd
Federal Deposit Insurance Corp
Security Inc

Dates

September 12, 2025
October 30, 2013
March 15, 2025
January 22, 2025
March 1, 2026
February 28, 2031

Amounts

$485
$50,000,000
$9,325,000
$18,650,000
$27,975,000

Obligations

Skybridge must cooperate with OCC examinations
Given the sensitivity and regulatory significance of this data, the SkyComply™ platform must be maintained in strict compliance with all applicable BSA/AML regulations, data protection requirements, and information security standards
On-site audits are permitted only upon a demonstrated material security concern — meaning that Meridian must articulate a specific, credible basis for believing that on-site access is necessary before it can exercise that right
However, the current draft has one significant gap that must be addressed: as currently drafted, Meridian's audit rights are limited to "security controls
While the SOC 2 Type II / ISO 27001 / questionnaire framework may continue to serve as the primary mechanism for exercising these rights in most circumstances, the contractual right itself must be broad enough to cover all relevant areas
In such cases, the banking organization's risk exposure extends beyond the third party itself to encompass the subcontractor chain, and the bank's risk management practices must account for this extended exposure