Independent technical review within state-supervised remediation
Mandated independent AML consultant
This is the qualified independent anti-money-laundering consultant role required by the multistate Block consent order. The retained record establishes assessment, prioritisation and validation duties but does not identify an appointed firm or engagement fee.
Mandated workflow
The order requires an assessment within nine months, followed by a corrective-action plan within 90 calendar days after assessment and immediate implementation. The consultant validates completion and supplies reports to Block and the state Executive Committee. For replacement, Block must notify the committee within ten calendar days after selection and engage the replacement within thirty days of that notification. The document does not impose a ten-day selection deadline or identify an express state veto over a named consultant.
selects replacement subject to independence and notice
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
II.D.8: company Compliance Management Committee must notify state Executive Committee within 10 calendar days after becoming aware of replacement need. Block must notify that committee within 10 calendar days AFTER making its selection, then engage the replacement within 30 calendar days of selection notification. No 10-day selection deadline is stated. Replacement must be qualified, independent and unaffiliated; no named firm, initial appointment method or express state veto established.
Mandated independent AML consultant → Required AML Corrective Action Plan
must assess, prioritize and validate corrections
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Mandated independent consultant assesses AML adequacy, prioritizes measures for CAP and validates completion. Assessment within nine months; CAP submitted within 90 calendar days after assessment with immediate implementation. Completion/extension provisions do not prove an actual deadline expired. No individual account-closure authority inferred.
State order Executive Committee → Mandated independent AML consultant
receives reports and may inspect workpapers
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Reports go contemporaneously to Block and committee; committee may request workpapers/work product and ask specified questions. It also receives CAP/company reporting and can request Board Reports. Receipt/inspection rights do not establish state appointment of consultant or formal CAP approval.
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Company must make relevant personnel, vendors, facilities and records accessible for the required assessment. Role and required access are established; firm identity, engagement price and actual inspections are unknown.
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Mandated independent consultant assesses AML adequacy, prioritizes measures for CAP and validates completion. Assessment within nine months; CAP submitted within 90 calendar days after assessment with immediate implementation. Completion/extension provisions do not prove an actual deadline expired. No individual account-closure authority inferred.
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Company must make relevant personnel, vendors, facilities and records accessible for the required assessment. Role and required access are established; firm identity, engagement price and actual inspections are unknown.
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
II.D.8: company Compliance Management Committee must notify state Executive Committee within 10 calendar days after becoming aware of replacement need. Block must notify that committee within 10 calendar days AFTER making its selection, then engage the replacement within 30 calendar days of selection notification. No 10-day selection deadline is stated. Replacement must be qualified, independent and unaffiliated; no named firm, initial appointment method or express state veto established.
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Reports go contemporaneously to Block and committee; committee may request workpapers/work product and ask specified questions. It also receives CAP/company reporting and can request Board Reports. Receipt/inspection rights do not establish state appointment of consultant or formal CAP approval.