{
  "body_html": "<h2>Customer Acceptance and Risk Categorization</h2>\n<ol>\n<li>Ask the customer for <strong>government-issued photo ID</strong> before processing any transaction.</li>\n<li>Record the customer's <strong>full name</strong>, <strong>current address</strong>, <strong>ID number</strong>, and <strong>date of birth</strong>.</li>\n<li>Screen the customer's name against the <strong>OFAC blocked-parties list</strong> before completing the transaction.</li>\n<li>Record the <strong>service type</strong> and <strong>transaction amount</strong>.</li>\n<li>Treat the customer as <strong>standard risk</strong> by default.</li>\n<li>Stop the transaction and notify your <strong>BSA/AML Compliance Officer</strong> immediately if you observe any of the following:</li>\n</ol>\n<ul>\n<li>The transaction amount does not match the customer's stated income or occupation.</li>\n<li>The customer requests a transaction structure with no clear legitimate purpose.</li>\n<li>The customer is a current or former foreign government official, senior political party leader, or executive of a state-owned enterprise.</li>\n<li>The customer is an immediate family member or close associate of such a person.</li>\n<li>The customer's primary residence or main business operations are in a <strong>high-risk or sanctioned country</strong>.</li>\n<li>The customer operates a <strong>money services business</strong>, currency dealer, or similar high-risk entity.</li>\n<li>A prior report or law enforcement inquiry involves this customer or a related party.</li>\n</ul>\n<ol>\n<li>Do not decide on your own whether to proceed with a flagged transaction. Your <strong>BSA/AML Compliance Officer</strong> makes that determination. Escalating protects <strong>Advanced Compliance Technology, Inc.</strong> and you from liability for improper transactions.</li>\n<li>If a non-commercial customer's single transaction exceeds <strong>$10,000</strong>, notify your <strong>BSA/AML Compliance Officer</strong> before completing it. Your <strong>BSA/AML Compliance Officer</strong> determines whether <strong>source-of-funds documentation</strong> is required.</li>\n</ol>",
  "narration_text": "Ask the customer for government-issued photo ID before processing any transaction.\r\nRecord the customer's full name, current address, ID number, and date of birth.\r\nScreen the customer's name against the OFAC blocked-parties list before completing the transaction.\r\nRecord the service type and transaction amount.\r\nTreat the customer as standard risk by default.\r\nStop the transaction and notify your BSA/AML Compliance Officer immediately if you observe any of the following:\r\n   - The transaction amount does not match the customer's stated income or occupation.\r\n   - The customer requests a transaction structure with no clear legitimate purpose.\r\n   - The customer is a current or former foreign government official, senior political party leader, or executive of a state-owned enterprise.\r\n   - The customer is an immediate family member or close associate of such a person.\r\n   - The customer's primary residence or main business operations are in a high-risk or sanctioned country.\r\n   - The customer operates a money services business, currency dealer, or similar high-risk entity.\r\n   - A prior report or law enforcement inquiry involves this customer or a related party.\r\nDo not decide on your own whether to proceed with a flagged transaction. Your BSA/AML Compliance Officer makes that determination. Escalating protects Advanced Compliance Technology, Inc. and you from liability for improper transactions.\r\nIf a non-commercial customer's single transaction exceeds $10,000, notify your BSA/AML Compliance Officer before completing it. Your BSA/AML Compliance Officer determines whether source-of-funds documentation is required."
}