Extract to table

However, the Order explicitly does not preclude any future referral, and the possibility remains a live risk factor that must be continuously monitored throughout the remediation period and beyond

The $14,500,000 CMP falls squarely within this provision and must be treated as a non-deductible expense for tax purposes

The remediation of OFAC screening coverage must therefore include not only achieving 100% screening across all BaaS channels but also optimizing the screening parameters to improve the signal-to-noise ratio

The OFAC module must be fully operational by November 1, 2025, providing a three-month window between platform deployment and full OFAC operationalization

• 100% Coverage Validation: BRB must develop and implement an OFAC remediation testing plan to validate screening coverage across all BaaS partners

The filing timeline is critical: a SAR must be filed with FinCEN no later than 30 days after the date of initial detection of facts that may constitute a basis for filing