{
  "body_html": "<h2>Customer and Account Closure</h2>\n<p>Before taking any closure action, complete these checks in order.</p>\n<p><strong>1. File the SAR first — if applicable</strong> If suspicious activity is involved, file the SAR on FinCEN Form 111 before any other step. Record the SAR filing reference in the case file. Do not proceed until the SAR is filed.</p>\n<p><strong>2. Check for an active 314(a) search</strong> Confirm no active FinCEN 314(a) search covers this customer. If a match exists, stop immediately. Follow Section 18 before doing anything else.</p>\n<p><strong>3. Check for an OFAC blocking order</strong> Confirm the account is not subject to an OFAC blocking order. If the account is blocked:</p>\n<ul>\n<li>Do not process standard closure.</li>\n<li>Move blocked funds to a segregated, interest-bearing account.</li>\n<li>File a blocking report with OFAC within 10 business days of the blocking action.</li>\n<li>Handle all OFAC correspondence for this account going forward.</li>\n<li>Keep the account open and restricted until OFAC authorizes disposition in writing.</li>\n</ul>\n<p><strong>4. Secure all records</strong> Confirm all transaction records, identification documents, and account files are preserved for the full required retention period. Closure does not reduce any retention obligation.</p>\n<p><strong>5. Review the closure communication</strong> Before sending any written or verbal communication, review it and remove any of the following:</p>\n<ul>\n<li>Reference to a SAR or suspicious activity</li>\n<li>Reference to a law enforcement inquiry, subpoena, or investigation</li>\n<li>Any language that could alert the customer to the compliance concern</li>\n</ul>\n<p>Permissible language states only that Advanced Compliance Technology, Inc. has made a business decision to end the relationship. Disclosing a SAR or its basis is unlawful tipping off and carries federal criminal liability.</p>\n<p><strong>6. Execute and document the closure</strong> Process the closure using business decision language only. Record the compliance basis, closure date, SAR filing reference (if applicable), and fund disposition in the case file.</p>",
  "narration_text": "Before taking any closure action, complete these checks in order.\r\n\r\nFile the SAR first — if applicable\r\nIf suspicious activity is involved, file the SAR on FinCEN Form 111 before any other step. Record the SAR filing reference in the case file. Do not proceed until the SAR is filed.\r\n\r\nCheck for an active 314(a) search\r\nConfirm no active FinCEN 314(a) search covers this customer. If a match exists, stop immediately. Follow Section 18 before doing anything else.\r\n\r\nCheck for an OFAC blocking order\r\nConfirm the account is not subject to an OFAC blocking order. If the account is blocked:\r\nDo not process standard closure.\r\nMove blocked funds to a segregated, interest-bearing account.\r\nFile a blocking report with OFAC within 10 business days of the blocking action.\r\nHandle all OFAC correspondence for this account going forward.\r\nKeep the account open and restricted until OFAC authorizes disposition in writing.\r\n\r\nSecure all records\r\nConfirm all transaction records, identification documents, and account files are preserved for the full required retention period. Closure does not reduce any retention obligation.\r\n\r\nReview the closure communication\r\nBefore sending any written or verbal communication, review it and remove any of the following:\r\nReference to a SAR or suspicious activity\r\nReference to a law enforcement inquiry, subpoena, or investigation\r\nAny language that could alert the customer to the compliance concern\r\n\r\nPermissible language states only that Advanced Compliance Technology, Inc. has made a business decision to end the relationship. Disclosing a SAR or its basis is unlawful tipping off and carries federal criminal liability.\r\n\r\nExecute and document the closure\r\nProcess the closure using business decision language only. Record the compliance basis, closure date, SAR filing reference (if applicable), and fund disposition in the case file."
}