Extract to table

While their individual transaction volumes are lower, the same architectural vulnerabilities potentially exist in their integrations, and each must be individually assessed and validated as part of this remediation plan

The specific technology integration failures that permitted approximately twelve percent (12%) of NovaPay transactions (and transactions from other BaaS partners) to bypass the OFAC screening engine must be eliminated through fundamental redesign of the API gateway architecture and transaction routing logic

All remediation activities must converge on the Consent Order deadline of November 1, 2025, by which date OFAC screening must be fully operational across all BaaS channels with demonstrated one hundred percent (100%) coverage

BRB's OFAC compliance policy, screening procedures manual, and BaaS-specific screening protocols must be comprehensively revised, and all relevant personnel — including BSA/AML staff, BaaS relationship managers, technology staff, and front-line employees — must be trained on the revised policies and procedures

This redesign must be comprehensive, covering every transaction type processed by every BaaS partner, and must be implemented in a manner that eliminates the possibility of future bypass due to integration changes or partner workflow modifications

The integration requirements are specific to each major BaaS partner and must address the unique transaction processing characteristics of each partner's platform: NovaPay Technologies Inc