Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / remediation-recommendations-memo.docx
remediation-recommendations-memo.docx
Parties
HARKNESS LLP
Torchlight Mining Corp
Pinnacle Forensic Advisory LLC
Torchlight Ganara Holdings Ltd
Crestfield Advisory Partners Ltd
Sharpe LLP
Clarendon Group LLP
Sentinel Compliance Solutions Inc
Dates
May 12, 2025
March 5, 2025
April 11, 2025
May 2, 2025
May 15, 2025
April 12, 2019
July 15, 2019
March 22, 2020
September 8, 2021
February 14, 2023
Amounts
$4,730,000
$14.19
$19.63
$3,210,000
$2,410,000
$890,000
$630,000
$800,000
$1,850,000
$620,000
Obligations
The VP Compliance and Ethics, or her designee, must provide written sign-off on the due diligence file before the engagement proceeds
Any material changes in the third party's ownership, personnel, or risk profile identified during re-certification must trigger a full enhanced or heightened due diligence review
All currently active third-party agents, consultants, and intermediaries globally must be subjected to due diligence under the new TDD Policy
The secondary approver must be independent of the business unit requesting the payment
All payments to intermediaries exceeding $50,000, regardless of the number and level of management approvals obtained, must be submitted to the VP Compliance and Ethics for review prior to processing
Torchlight's ERP and accounting software must be configured to prevent the processing of payments that lack the required number and level of approvals