What the records show
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.
Block Board compliance responsibility → Required AML Corrective Action Plan
must formally approve corrective action plan
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Board or authorized committee has formal CAP approval and ultimate compliance responsibility. CAP is submitted to state Executive Committee; receipt is not an express additional CAP approval requirement. Actual plan and approval not acquired.
State order Executive Committee → Required AML Corrective Action Plan
may extend reporting deadlines on good cause
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
II.D.9 allows reporting extensions on reasonable-ground request/good cause. CAP-duration extension instead has consultant review/documentation under II.D.2(c). No actual extension or unconditional state veto over every plan established.
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What the connections say
3 relationships1Block Board compliance responsibility → must formally approve corrective action plan → Required AML Corrective Action Plan
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Board or authorized committee has formal CAP approval and ultimate compliance responsibility. CAP is submitted to state Executive Committee; receipt is not an express additional CAP approval requirement. Actual plan and approval not acquired.
Read the original source 1
Mandated independent AML consultant → must assess, prioritize and validate corrections → Required AML Corrective Action Plan
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.
Read the original source 1
State order Executive Committee → may extend reporting deadlines on good cause → Required AML Corrective Action Plan
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
II.D.9 allows reporting extensions on reasonable-ground request/good cause. CAP-duration extension instead has consultant review/documentation under II.D.2(c). No actual extension or unconditional state veto over every plan established.
Read the original source 1