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The financial significance of this business line underscores both the urgency and the complexity of the compliance remediation effort: BRB must achieve full regulatory compliance while maintaining the commercial viability of its fintech partnerships

This principle is foundational to the framework set forth in this memorandum and must be reinforced throughout BRB's compliance infrastructure

While fintech partners may be contractually required to implement first-line AML controls — such as customer identification procedures, transaction monitoring, and suspicious activity escalation — BRB cannot delegate its ultimate compliance responsibility and must maintain oversight sufficient to ensure that partner-performed functions meet regulatory standards

This gap was specifically cited in the Consent Order and represents a governance failure that must be addressed as a priority

Each Tier 1 partner must provide monthly compliance reports to BRB, delivered no later than the fifteenth (15th) calendar day of the following month

All transaction flows originating from or processed through Tier 1 partner platforms — including wire transfers, ACH transactions, card transactions, and P2P transfers — must be subject to real-time OFAC sanctions screening