Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / revised-ofac-compliance-policy-draft.docx
revised-ofac-compliance-policy-draft.docx
Parties
NovaPay Technologies Inc
FairLend Digital LLC
VaultEdge Inc
Veridian Analytics Inc
OFAC SA
Harkness LLP
BaaS-related SA
Dates
January 15, 2025
February 15, 2026
November 1, 2025
August 1, 2025
May 15, 2025
October 1, 2025
Amounts
$74.3
$30.5
Obligations
Given the scale and velocity of BaaS transaction flows, the Bank's OFAC compliance program must be calibrated to address the unique risks posed by these channels
All personnel must understand that OFAC sanctions violations are subject to a strict liability standard
The Compliance Committee is chaired by James Rutherford and shall receive monthly reporting on OFAC screening metrics
The Board must approve this Policy and any material amendments thereto
The Board shall receive a comprehensive quarterly OFAC program status report, in addition to the monthly reports provided to the Compliance Committee, and shall ensure that the Bank's OFAC compliance program is adequately resourced and that any identified deficiencies are remediated in a timely manner
OFAC screening performance data presented to the Board and Compliance Committee shall be segmented by business line and by individual BaaS partner to enable effective oversight and identification of partner-specific risks or deficiencies