Extract to table

The key milestone for backlog clearance is June 30, 2025, by which date all 2,400 unreviewed alerts must be fully reviewed, dispositioned, and, where warranted, associated SAR filings completed and submitted to FinCEN

The prospect of a separate FinCEN enforcement action remains a material risk that must be managed through demonstrated, tangible progress on SAR remediation, timely and transparent reporting, and careful privilege management

This standard applies on a rolling average basis, measured monthly, and must be achieved on a sustained basis commencing no later than August 1, 2025

Any suspicious activity identified through the lookback process must be documented and a SAR filed within 30 days of the date on which the activity is identified as suspicious, consistent with the general 30-day filing standard

1 Scope and Purpose In addition to the clearance of the existing alert backlog, a comprehensive lookback is required to identify potentially suspicious activity that was not detected, investigated, or reported during the period when BRB's SAR processes were deficient

While this workload figure may appear manageable in the abstract, it must be understood in the context of the complexity and documentation requirements associated with each alert investigation