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