{
  "body_html": "<h2>SAR, CTR, and CMIR Filing</h2>\n<p>File a SAR for any transaction at or through Advanced Compliance Technology, Inc. involving $2,000 or more when funds appear to be from illegal activity, the transaction is designed to evade BSA requirements, no apparent lawful purpose exists, or the transaction facilitates criminal activity. Escalate suspicious transactions to the BSA/AML Compliance Officer the same business day. The BSA/AML Compliance Officer reviews all available facts, the customer record, and prior SAR history, then decides whether to file. Document the decision and rationale regardless of outcome.</p>\n<p>File FinCEN Form 111 via BSA E-Filing within 30 calendar days of initial detection. When no suspect is identified, you may delay filing while attempting to identify a suspect, but the outer deadline is 60 calendar days from initial detection. For ongoing suspicious activity, file a continuing SAR every 90 days and cite the original SAR in each filing. When activity requires immediate law enforcement attention, contact the appropriate agency by telephone before or at the same time as the SAR filing.</p>\n<p>Retain the SAR and all supporting documentation for five years from the filing date. Never disclose a SAR or reveal that one has been filed. If a subpoena demands a SAR or related records, decline production and notify FinCEN promptly.</p>\n<p>File a CTR for each currency transaction that exceeds $10,000. Aggregate multiple currency transactions by or on behalf of the same person on the same business day across all Advanced Compliance Technology, Inc. locations. When the aggregate exceeds $10,000, the transaction is reportable. Collect the customer's name, address, date of birth, and government-issued photo ID number before completing the transaction. File FinCEN Form 112 via BSA E-Filing within 15 calendar days of the transaction date. Retain the CTR for five years from the filing date.</p>\n<p>File FinCEN Form 105 for any physical transport of currency or monetary instruments exceeding $10,000 into or out of the United States. Florida requires filing via BSA E-Filing within 15 calendar days of the transport date.</p>\n<p>When you detect indicators of structuring, report to the BSA/AML Compliance Officer immediately. The BSA/AML Compliance Officer evaluates the activity for SAR filing. Structuring is itself a reportable event. No employee may cause Advanced Compliance Technology, Inc. to fail to file a required report or file a materially incomplete report.</p>\n<p>Florida imposes criminal penalties for structuring by money services businesses. Structuring above $300 is a third-degree felony. Structuring above $20,000 is a second-degree felony. Structuring above $100,000 is a first-degree felony. These penalties apply to employees who assist in structuring.</p>",
  "narration_text": "File a SAR for any transaction at or through Advanced Compliance Technology, Inc. involving $2,000 or more when funds appear to be from illegal activity, the transaction is designed to evade BSA requirements, no apparent lawful purpose exists, or the transaction facilitates criminal activity. Escalate suspicious transactions to the BSA/AML Compliance Officer the same business day. The BSA/AML Compliance Officer reviews all available facts, the customer record, and prior SAR history, then decides whether to file. Document the decision and rationale regardless of outcome.\r\n\r\nFile FinCEN Form 111 via BSA E-Filing within 30 calendar days of initial detection. When no suspect is identified, you may delay filing while attempting to identify a suspect, but the outer deadline is 60 calendar days from initial detection. For ongoing suspicious activity, file a continuing SAR every 90 days and cite the original SAR in each filing. When activity requires immediate law enforcement attention, contact the appropriate agency by telephone before or at the same time as the SAR filing.\r\n\r\nRetain the SAR and all supporting documentation for five years from the filing date. Never disclose a SAR or reveal that one has been filed. If a subpoena demands a SAR or related records, decline production and notify FinCEN promptly.\r\n\r\nFile a CTR for each currency transaction that exceeds $10,000. Aggregate multiple currency transactions by or on behalf of the same person on the same business day across all Advanced Compliance Technology, Inc. locations. When the aggregate exceeds $10,000, the transaction is reportable. Collect the customer's name, address, date of birth, and government-issued photo ID number before completing the transaction. File FinCEN Form 112 via BSA E-Filing within 15 calendar days of the transaction date. Retain the CTR for five years from the filing date.\r\n\r\nFile FinCEN Form 105 for any physical transport of currency or monetary instruments exceeding $10,000 into or out of the United States. Florida requires filing via BSA E-Filing within 15 calendar days of the transport date.\r\n\r\nWhen you detect indicators of structuring, report to the BSA/AML Compliance Officer immediately. The BSA/AML Compliance Officer evaluates the activity for SAR filing. Structuring is itself a reportable event. No employee may cause Advanced Compliance Technology, Inc. to fail to file a required report or file a materially incomplete report.\r\n\r\nFlorida imposes criminal penalties for structuring by money services businesses. Structuring above $300 is a third-degree felony. Structuring above $20,000 is a second-degree felony. Structuring above $100,000 is a first-degree felony. These penalties apply to employees who assist in structuring."
}