Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / revised-sar-policy-procedures-draft.docx
revised-sar-policy-procedures-draft.docx
Parties
Harkness LLP
BRB SA
Two SA
BRB's SA
FairLend Digital LLC
Pinnacle Compliance Solutions LLC
Pope LLP
Continuing SA
Dates
January 15, 2025
May 15, 2025
August 1, 2025
February 27, 2025
February 28, 2025
October 1, 2025
June 30, 2025
September 15, 2025
December 15, 2025
March 31, 2025
Amounts
$14,500,000
$5,500,000
$5,000
$2,250,000
$150,000
$10,000
$3,600,000
$2,800,000
$1,900,000
$6,000,000
Obligations
3 Regulatory Background and Context This Policy is issued against, and must be read in the context of, the following regulatory history: (a) June 2022 — MRA
Upon effectiveness, the March 2022 Policy shall be retired and archived in accordance with Section 15
6 SAR Program Staffing The SAR program shall be staffed in accordance with the following framework, which reflects the Bank's remediation-period plan: (a) Permanent BSA/AML Department (Current): 62 FTEs
2 Alert Triage and Assignment Every Alert generated by the transaction monitoring system shall be triaged within two (2) business days of the Alert Generation Date
1) shall be assigned to a senior investigator within one (1) business day of triage
Medium- and low-priority Alerts shall be assigned within three (3) business days of triage