{
  "body_html": "<h2>Regulatory Examinations and Enforcement</h2>\n<p>Florida examines every {{license_type}} licensee at least once every five years. Stay examination-ready at all times.</p>\n<p><strong>Maintain your Document Inventory continuously:</strong></p>\n<ol>\n<li>Organize it by service line, location, record type, and date range.</li>\n<li>Update it every quarter.</li>\n<li>Include: customer identification files, transaction records, CTR filings, SAR filings, OFAC screening and blocking logs, monitoring documentation, agent audit records, prior examination findings and remediation evidence, and staff training acknowledgments.</li>\n<li>When the OFR requests records, produce everything requested within <strong>three business days</strong>.</li>\n</ol>\n<p><strong>When you receive examination notice, review these six areas:</strong></p>\n<ol>\n<li>Customer identification file completeness</li>\n<li>Monitoring documentation — exception logs, escalation records, SAR and CTR filings</li>\n<li>OFAC screening logs — hit resolution records and blocking documentation</li>\n<li>Agent audit documentation — current delegate audit status</li>\n<li>Prior examination findings and remediation completion evidence</li>\n<li>Regulatory change file — program updates adopted since the last examination</li>\n</ol>\n<p><strong>Before the examination begins:</strong></p>\n<ol>\n<li>Brief all staff on examination expectations and response protocols.</li>\n<li>Enforce the <strong>CCO-only communication rule</strong>: no staff member, officer, or owner may speak with OFR examiners without your presence or your prior express authorization. All examiner contact goes through you.</li>\n</ol>\n<p><strong>After receiving examination findings:</strong></p>\n<ol>\n<li>Within <strong>five business days</strong>, deliver a written summary to the owner or principal covering all findings and OFR observations.</li>\n<li>For each finding, prepare a written <strong>Corrective Action Plan</strong> that includes: the finding and its root cause, corrective action steps and responsible parties, target completion date, and evidence of completion.</li>\n<li>Report corrective action status to the owner or principal <strong>quarterly</strong> until all findings are fully resolved and documented.</li>\n</ol>\n<p><strong>Penalties for violations are serious:</strong></p>\n<ul>\n<li>First offense: $1,000–$3,500 fine, 3–10 day suspension</li>\n<li>Second offense: $3,500–$7,500 fine, 10–20 day suspension</li>\n<li>Third or subsequent offense: $7,500–$10,000 fine, 20–30 day suspension, possible revocation</li>\n</ul>\n<p>Additional consequences include license denial, license suspension, license revocation, cease and desist orders, restitution orders, and removal of a control person. Advanced Compliance Technology, Inc.'s document inventory, trained staff, and defined escalation structure are your primary tools for avoiding these outcomes.</p>",
  "narration_text": "Florida examines every {{license_type}} licensee at least once every five years. Stay examination-ready at all times.\r\n\r\nMaintain your Document Inventory continuously:\r\n\r\nOrganize it by service line, location, record type, and date range.\r\nUpdate it every quarter.\r\nInclude: customer identification files, transaction records, CTR filings, SAR filings, OFAC screening and blocking logs, monitoring documentation, agent audit records, prior examination findings and remediation evidence, and staff training acknowledgments.\r\nWhen the OFR requests records, produce everything requested within three business days.\r\n\r\nWhen you receive examination notice, review these six areas:\r\n\r\nCustomer identification file completeness\r\nMonitoring documentation — exception logs, escalation records, SAR and CTR filings\r\nOFAC screening logs — hit resolution records and blocking documentation\r\nAgent audit documentation — current delegate audit status\r\nPrior examination findings and remediation completion evidence\r\nRegulatory change file — program updates adopted since the last examination\r\n\r\nBefore the examination begins:\r\n\r\nBrief all staff on examination expectations and response protocols.\r\nEnforce the CCO-only communication rule: no staff member, officer, or owner may speak with OFR examiners without your presence or your prior express authorization. All examiner contact goes through you.\r\n\r\nAfter receiving examination findings:\r\n\r\nWithin five business days, deliver a written summary to the owner or principal covering all findings and OFR observations.\r\nFor each finding, prepare a written Corrective Action Plan that includes: the finding and its root cause, corrective action steps and responsible parties, target completion date, and evidence of completion.\r\nReport corrective action status to the owner or principal quarterly until all findings are fully resolved and documented.\r\n\r\nPenalties for violations are serious:\r\n\r\nFirst offense: $1,000–$3,500 fine, 3–10 day suspension\r\nSecond offense: $3,500–$7,500 fine, 10–20 day suspension\r\nThird or subsequent offense: $7,500–$10,000 fine, 20–30 day suspension, possible revocation\r\n\r\nAdditional consequences include license denial, license suspension, license revocation, cease and desist orders, restitution orders, and removal of a control person. Advanced Compliance Technology, Inc.'s document inventory, trained staff, and defined escalation structure are your primary tools for avoiding these outcomes."
}