FR EA

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

Extract to table / board-senior-management-bsa-aml-training-outline.docx
board-senior-management-bsa-aml-training-outline.docx · 1045-00002

Parties

HARKNESS LLP
Thornfield Consulting Group LLC
FinCEN's Corp
Bank's SA
Pope LLP
OFAC SA
NovaPay Technologies Inc
The SA

Dates

February 10, 2025
January 15, 2025
May 15, 2025
February 5, 2025
February 15, 2026
October 26, 2001
September 11, 2001
January 1, 2021
November 1, 2025
March 16, 2025

Amounts

$14,500,000
$1,800,000
$42,500,000
$10,000
$5,000
$3,000
$1,000,000
$100,000,000
$1,100,000
$30.5

Obligations

This training is a component of Workstream 5 (BSA/AML Program Governance & Training Enhancement) of the Comprehensive Remediation Action Plan ("RAP") that BRB is required to submit to the OCC by May 15, 2025
OCC-2025-003, so that each Board member and senior officer can articulate the nature and scope of the deficiencies identified by the OCC, the remediation requirements imposed, and the critical milestones and deadlines that must be met over the ensuing twelve-month period
All Board members and C-suite officers must complete their initial training sessions prior to the May 15, 2025 RAP submission deadline
Any Board member or senior officer who is unable to attend the scheduled session must complete a make-up session, to be arranged by BRB General Counsel Gregory Nardone and documented in the same manner
Every national bank is required to establish and maintain a BSA/AML compliance program that is reasonably designed to ensure and monitor compliance with the BSA and its implementing regulations
Multiple transactions conducted by or on behalf of the same person during a single business day must be aggregated if they total more than $10,000 in the aggregate