FR EA

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Extract to table / veridian-sow-ofac-module-enhancement.docx
veridian-sow-ofac-module-enhancement.docx · 1045-00002

Parties

Harkness LLP
Veridian Analytics Inc
NovaPay Technologies Inc
Pope LLP
FairLend Digital LLC
VaultEdge Inc
Thornfield Consulting Group LLC
FinCEN SA

Dates

September 1, 2023
January 15, 2025
November 1, 2025
May 15, 2025
August 1, 2025
January 31, 2026
October 1, 2025

Amounts

$74.3
$30.5
$1.4
$9.7

Obligations

The OFAC module enhancement is a core component of BRB's Comprehensive Remediation Action Plan (the "Action Plan"), which BRB is required to submit to the OCC by May 15, 2025, in compliance with the Consent Order
The commitments and timelines set forth in this SOW will be reflected in the Action Plan and must therefore be achievable and realistic
The Enhanced OFAC Module must be fully operational for all BaaS channels no later than November 1, 2025, per the Consent Order timeline
In the event of any conflict between this SOW and the MSA (as amended), the MSA shall govern, except where this SOW expressly provides more specific requirements applicable to the OFAC Module enhancement, in which case the more specific provisions of this SOW shall control to the extent of the inconsistency
SECTION 2: DEFINITIONS Capitalized terms used in this SOW and not otherwise defined herein shall have the meanings ascribed to them in the MSA (Contract No
1 Overview Veridian shall design, develop, configure, test, deploy, and support the Enhanced OFAC Module as a fully integrated component of Veridian TMS v