Extract to table

Any determination to expand the lookback scope based on backlog triage findings must be approved by Thomas Ikeda (BSA Officer), Patricia Langston (CCO), and Philip Hartmann (Calderwood & Harkness), and must be communicated to Thornfield Consulting Group for incorporation into its independent assessment

Given that these transactions were not subjected to OFAC screening at the time of processing, any suspicious activity alert generated in connection with such transactions must be treated as potentially involving sanctioned parties or jurisdictions until screening is confirmed and cleared

• Potential Criminal Activity: Any alert where the investigation reveals indicators of potential criminal activity — including but not limited to fraud, money laundering, structuring, terrorism financing, tax evasion, or corruption — must be escalated to Thomas Ikeda within 24 hours of the identification of such indicators, regardless of the alert's triage category

• Insider Involvement: Any alert where the investigation reveals that the SAR filing may involve a BRB insider, director, officer, or employee must be escalated to Thomas Ikeda and Gregory Nardone (General Counsel) immediately upon identification

These filings must be handled by a restricted group of authorized personnel to prevent tipping off the subject

3 Escalation to Chief Compliance Officer (Patricia Langston) Patricia Langston, as Chief Compliance Officer, is responsible for enterprise-level compliance oversight and serves as the escalation point for systemic and program-level findings: • Systemic Patterns: Any patterns or clusters of related alerts that suggest systemic failures in the transaction monitoring program, customer onboarding processes, or BaaS partner oversight must be escalated to Patricia Langston