{
  "body_html": "<h2>Regulatory Examinations and Enforcement</h2>\n<p>Florida examines each {{license_type}} licensee at least once every five years. Maintain examination readiness at all times — not only when an examination is approaching.</p>\n<p>Keep a Document Inventory organized by service line, location, record type, and date range. Update it quarterly. The inventory must cover: 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. When the OFR issues a document request, produce all requested records within three business days.</p>\n<p>When you receive examination notice, conduct a pre-examination review across six areas:</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>Before the examination begins, brief all staff on examination expectations and response protocols. Enforce the CCO-only communication rule: no staff member, officer, or owner may speak with OFR examiners about examination matters without your presence or your prior express authorization. All examiner contact goes through you.</p>\n<p>Within five business days of receiving examination findings, deliver a written summary to the owner or principal covering all findings and OFR observations. For each finding, prepare a written Corrective Action Plan that specifies: the finding and its root cause; corrective action steps and responsible parties; the target completion date; and evidence of completion. Report corrective action status to the owner or principal quarterly until all findings are resolved and documented.</p>\n<p>OFR enforcement penalties range from $1,000 to $10,000 per violation on a graduated schedule:</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, revocation possible</li>\n</ul>\n<p>Additional remedies 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 each {{license_type}} licensee at least once every five years. Maintain examination readiness at all times — not only when an examination is approaching.\r\n\r\nKeep a Document Inventory organized by service line, location, record type, and date range. Update it quarterly. The inventory must cover: 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. When the OFR issues a document request, produce all requested records within three business days.\r\n\r\nWhen you receive examination notice, conduct a pre-examination review across 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, brief all staff on examination expectations and response protocols. Enforce the CCO-only communication rule: no staff member, officer, or owner may speak with OFR examiners about examination matters without your presence or your prior express authorization. All examiner contact goes through you.\r\n\r\nWithin five business days of receiving examination findings, deliver a written summary to the owner or principal covering all findings and OFR observations. For each finding, prepare a written Corrective Action Plan that specifies: the finding and its root cause; corrective action steps and responsible parties; the target completion date; and evidence of completion. Report corrective action status to the owner or principal quarterly until all findings are resolved and documented.\r\n\r\nOFR enforcement penalties range from $1,000 to $10,000 per violation on a graduated schedule:\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, revocation possible\r\n\r\nAdditional remedies 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."
}