Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / investigation-findings-memo.docx
investigation-findings-memo.docx
Parties
HARKNESS LLP
Sentinel Compliance Data Services Ltd
Lansheng Harborline Technologies Technologies Ltd
Ashford Pennington LLC
HSAG's SA
Whitfield LLP
Braxton Merritt LLP
Dates
January 28, 2026
August 3, 2025
June 14, 2025
February 15, 2020
March 12, 2024
May 22, 2025
November 22, 2025
December 19, 2025
February 5, 2026
October 18, 2025
Amounts
$1,197,000. 2
$412,000
$387,000
$398,000
$1,197,000
$4.41
$401,000
$2.42
$403,000
$1.5
Obligations
HSAG and HSI shall perform independent restricted-party screening of all Archipelago PRC-destined orders in parallel with Archipelago's own screening
Any change to the restricted-party screening database during the order lifecycle shall trigger an automatic re-screen of all open orders
The database update SLA in the Archipelago–Sentinel Master Services Agreement shall be amended from 5 business days to 2 business days, with automated alerts to Archipelago's and HSAG's compliance teams if the SLA is breached
HSAG shall conduct semi-annual audits of Sentinel's SLA compliance
The additional staff shall be in place prior to the effective date of any settlement agreement
Audit findings shall be reported to HSAG's Head of Trade Compliance and to the General Counsel