Extract to table

This reservation of rights is a material factor that must inform every element of our regulatory engagement strategy going forward

The Consent Order must be understood in the context of an escalating supervisory history that is likely to be of significant concern to FinCEN

Even seemingly routine interactions can become significant in the context of an enforcement investigation, and we must have a complete picture before proceeding

320, which sets forth the specific circumstances under which a SAR must be filed, the content requirements for SAR filings, and the timing requirements

Accordingly, any statements made by BRB or its counsel to FinCEN — whether in formal submissions, informal conversations, or voluntary disclosures — must be crafted with the awareness that they may become available to DOJ prosecutors and may be used in a criminal proceeding

The line between "proactive and transparent" and "undisciplined and overinclusive" is critical, and all communications must be reviewed and approved by C&H before transmission