Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / comprehensive-remediation-action-plan-draft.docx
comprehensive-remediation-action-plan-draft.docx
Parties
Harkness LLP
Thornfield Consulting Group LLC
Pope LLP
BRB's SA
OFAC SA
NovaPay Technologies Inc
Drayton Mercer LLP
Veridian Analytics Inc
Dates
May 15, 2025
January 15, 2025
April 15, 2025
December 31, 2024
March 16, 2025
March 14, 2025
February 28, 2025
February 10, 2025
February 15, 2026
May 16, 2025
Amounts
$38.7
$29.4
$74.3
$127.4
$14.5
$42.5
$57.0
$14,500,000
$500,000
$4,800,000
Obligations
The Bank is required to submit to the OCC a comprehensive remediation action plan within 120 days of the effective date (i
The Bank is required to achieve 100% screening coverage for all transactions across all business lines, including all BaaS partner channels, by no later than November 1, 2025
The Bank must implement real-time screening capabilities for wire, ACH, card, and all BaaS partner transaction flows and must adopt revised OFAC compliance policies and procedures
The Bank is required to clear the existing backlog of approximately 2,400 unreviewed suspicious activity alerts by no later than June 30, 2025
The Bank must reduce its average SAR filing time to within 30 days of alert generation on a sustained basis and must conduct a comprehensive lookback review to identify any potentially suspicious activity that was missed during the period in which the backlog accumulated
The Bank must revise its CDD/EDD policies and procedures for all channels, including BaaS, and must establish clear responsibility allocations between the Bank and its fintech partners