Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / regulatory-risk-assessment-memorandum.docx
regulatory-risk-assessment-memorandum.docx
Parties
HARKNESS LLP
BRB's NovaPay Technologies Inc
Drayton Mercer LLP
Pope LLP
Thornfield Consulting Group LLC
BRB's SA
SAR Filing Deficiencies The SA
Pinnacle Compliance Solutions LLC
Dates
February 28, 2025
January 15, 2025
March 16, 2025
May 15, 2025
September 15, 2025
February 10, 2025
February 5, 2025
March 1, 2025
April 15, 2025
December 31, 2024
Amounts
$38.7
$127.4
$74.3
$14,500,000
$42,500,000
$57,000,000
$29.4
$412
$47.82
$41.15
Obligations
The willfulness requirement is a critical threshold: DOJ must establish that the defendant knew of and deliberately violated a legal duty, or acted with reckless disregard of a known legal obligation
Any such activity must be immediately referred for SAR filing and subject to C&H legal analysis regarding disclosure and cooperation obligations