Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / annotated-consent-order-summary.docx
annotated-consent-order-summary.docx
Parties
Harkness LLP
Drayton Mercer LLP
Pope LLP
BRB's SA
NovaPay Technologies Inc
Veridian Analytics Inc
Ridgeline Data Systems LLC
While SA
Dates
February 14, 2025
January 15, 2025
February 10, 2025
May 15, 2025
December 31, 2024
November 1, 2025
August 1, 2025
March 7, 2025
March 31, 2025
June 30, 2025
Amounts
$38.7
$29.4
$18.2
$1.1
$30.5
$2.8
$1.9
$4.1
$6.0
$7.2
Obligations
This memorandum cross-references the five core deficiency categories identified above to the corresponding remediation workstreams that are being developed for inclusion in the Comprehensive Remediation Action Plan ("RAP"), which BRB is required to submit to the OCC by May 15, 2025
BRB shall upgrade or replace its sanctions screening technology to eliminate the screening gaps identified in the Consent Order
The upgraded or replacement system must be capable of processing all transaction types across all channels without coverage gaps
The protocols must ensure timely integration of list updates into the screening system
BRB shall conduct comprehensive testing to validate 100% BaaS transaction screening coverage following implementation of the upgraded or replacement screening system
Testing results must be documented and made available to the OCC upon request