{
  "body_html": "<h2>Independent Review</h2>\n<p>The independent review is a check on your company's AML compliance program. \"Independent\" means the person doing the review must not report to the BSA/AML Compliance Officer. This separation is required. Any conflict of interest must be documented and resolved before the review begins. If a conflict is not resolved, the review results are invalid.</p>\n<p>You and senior management set the review scope together. The scope must match Advanced Compliance Technology, Inc.'s risk level and services. The review must cover policies, customer due diligence, transaction monitoring, SAR and CTR filings, recordkeeping, and staff training. It must also check the status of any problems found in the previous review.</p>\n<p>During the review, give the reviewer full access to systems, records, and people. Restricted access produces incomplete findings.</p>\n<p>The reviewer sends the written report directly to senior management — not to you. Senior management then assigns an owner and a deadline to fix each problem found. You must maintain a log of all open items. You must report the status of those fixes at every compliance reporting cycle until every item is closed.</p>\n<p>Keep the review report, all supporting records, and the remediation log for at least five years. Examiners may ask for past cycles at any time.</p>\n<p>The Florida licensing authority examines {{license_type}} licensees at intervals not exceeding five years. All problems found must be fixed before the next scheduled examination. Do not wait for an examination notice to organize your records. Keep everything ready at all times.</p>",
  "narration_text": "The independent review is a check on your company's AML compliance program. \"Independent\" means the person doing the review must not report to the BSA/AML Compliance Officer. This separation is required. Any conflict of interest must be documented and resolved before the review begins. If a conflict is not resolved, the review results are invalid.\r\n\r\nYou and senior management set the review scope together. The scope must match Advanced Compliance Technology, Inc.'s risk level and services. The review must cover policies, customer due diligence, transaction monitoring, SAR and CTR filings, recordkeeping, and staff training. It must also check the status of any problems found in the previous review.\r\n\r\nDuring the review, give the reviewer full access to systems, records, and people. Restricted access produces incomplete findings.\r\n\r\nThe reviewer sends the written report directly to senior management — not to you. Senior management then assigns an owner and a deadline to fix each problem found. You must maintain a log of all open items. You must report the status of those fixes at every compliance reporting cycle until every item is closed.\r\n\r\nKeep the review report, all supporting records, and the remediation log for at least five years. Examiners may ask for past cycles at any time.\r\n\r\nThe Florida licensing authority examines {{license_type}} licensees at intervals not exceeding five years. All problems found must be fixed before the next scheduled examination. Do not wait for an examination notice to organize your records. Keep everything ready at all times."
}