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Extract to table / memo-temporary-staff-supervision-qc.docx
memo-temporary-staff-supervision-qc.docx
Parties
HARKNESS LLP
Pinnacle Compliance Solutions LLC
Thornfield Consulting Group LLC
The SA
Interim SA
BRB's SA
Deficient SA
Pope LLP
Dates
February 20, 2025
January 15, 2025
May 15, 2025
June 30, 2025
March 31, 2025
July 15, 2025
January 15, 2026
September 15, 2025
March 1, 2025
April 15, 2025
Amounts
$3,600,000
$10,000
$5,500,000
$4,300,000
$30.5
$1.4
$500,000
$100,000
$1,000,000
Obligations
The following key milestones and deadlines govern the remediation timeline and directly affect the scope and urgency of the Pinnacle engagement: SAR Backlog Remediation: • Backlog Clearance Target: June 30, 2025 — All approximately 2,400 unreviewed suspicious activity alerts (as of the September 2024 baseline) must be dispositioned by this date
To ensure effective day-to-day oversight across the 30-FTE temporary workforce, BRB shall assign at least three (3) senior BSA/AML analysts as dedicated team leads, each overseeing approximately ten (10) Pinnacle FTEs
The following requirements apply to the designation of team leads: • All team leads must be permanent BRB employees
• Team lead assignments must be documented and communicated to Pinnacle's on-site engagement manager and to Calderwood & Harkness LLP
The Compliance Committee shall receive summary reports on temporary staffing quality, productivity, and milestone progress at each of its monthly meetings
• On-Site Engagement Manager: Pinnacle shall designate an on-site engagement manager who will be present at BRB's offices during normal business hours throughout the engagement period