FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / revised-cdd-edd-policy-draft.docx
revised-cdd-edd-policy-draft.docx · 1045-00002

Parties

Harkness LLP
Thornfield Consulting Group LLC
Pope LLP
Pinnacle Compliance Solutions LLC
NovaPay Technologies Inc
FairLend Digital LLC
VaultEdge Inc

Dates

January 15, 2025
May 11, 2018
February 28, 2025
June 30, 2025
April 15, 2025
February 15, 2026
July 15, 2025
January 15, 2026
August 1, 2025

Amounts

$500
$30.5
$1.4

Obligations

4 Definitions For the purposes of this policy, the following terms shall have the meanings set forth below
Terms defined in the BSA, FinCEN regulations, OFAC regulations, or the Consent Order that are used but not separately defined herein shall have the meanings ascribed to them in those authorities
The Audit Committee of the BRFG Board of Directors, chaired by Margaret Dao, and the Risk Committee, chaired by Arthur Connelly, shall each receive quarterly reporting on CDD/EDD program metrics as part of the consolidated BSA/AML compliance dashboard
The Compliance Committee shall have the authority and responsibility to review and approve this policy, and any material amendments hereto, prior to implementation
These temporary analysts operate under the direct supervision of the BSA Officer and designated BSA/AML supervisors within BRB, must complete all required training before commencing work, and are subject to the same quality assurance standards as BRB permanent staff
All amendments shall be documented with a version history, and the amended policy shall be promptly distributed to all affected personnel and BaaS partners