Extract to table

The Consent Order establishes a compliance deadline of November 1, 2025, by which date OFAC screening must be fully operational for all BaaS channels

The principle underlying this Plan is that every transaction processed through the Bank's charter, regardless of the originating fintech partner, transaction type, or payment rail, must be screened against all applicable OFAC sanctions lists prior to completion

incoming wires, incoming ACH credits) must be screened to identify potential sanctions exposure associated with the originator or originating institution

outgoing wires, ACH debits initiated by end-users) must be screened to identify potential sanctions exposure associated with the beneficiary or receiving institution

OFAC Lists to Be Screened The OFAC screening system must screen all in-scope transactions and customers/counterparties against the following OFAC-administered sanctions lists: • Specially Designated Nationals and blocked Persons List ("SDN List"): The primary OFAC sanctions list, which identifies individuals and entities whose assets must be blocked and with whom U

0 system must ingest all OFAC list updates within twenty-four (24) hours of their publication by OFAC