{
  "body_html": "<h2>Independent Review</h2>\n<p>Advanced Compliance Technology, Inc. maintains an independent review of its AML/CFT program. The reviewer must have no operational reporting relationship to the BSA/AML Compliance Officer. You do not perform this review.</p>\n<p>Before review work begins, confirm the reviewer's independence. Document any conflicts of interest and resolve them before work starts. Unresolved conflicts can invalidate the findings.</p>\n<p>Work with senior management to define the review scope. The scope must match Advanced Compliance Technology, Inc.'s risk level and current service profile. It must cover all of the following:</p>\n<ul>\n<li>AML/CFT policies, procedures, and internal controls</li>\n<li>CIP and customer due diligence</li>\n<li>OFAC screening and alert disposition</li>\n<li>Transaction monitoring and case handling</li>\n<li>SAR and CTR filing accuracy and timeliness</li>\n<li>Recordkeeping completeness and retention</li>\n<li>Training program adequacy and staff completion</li>\n<li>Status of all prior-cycle findings and remediation</li>\n</ul>\n<p>During the review, provide full access to systems, records, and personnel. Restricted access produces incomplete findings.</p>\n<p>The reviewer delivers the written report directly to senior management. The report does not route through you.</p>\n<p>Senior management assigns an owner and a target completion date for each deficiency. You maintain a remediation log for all open items. Report remediation status at each compliance reporting cycle until every item is closed.</p>\n<p>Retain the review report, supporting workpapers, and remediation records for a minimum of five years. Examiners may request prior-cycle documentation during any examination.</p>\n<p>Keep all program documentation and evidence files examination-ready at all times. Do not assemble documentation in response to an examination notice. The Florida licensing authority examines {{license_type}} licensees at intervals not exceeding five years. Map each review cycle to examiner guidelines. All deficiencies must be remediated before the next scheduled examination.</p>",
  "narration_text": "Advanced Compliance Technology, Inc. maintains an independent review of its AML/CFT program. The reviewer must have no operational reporting relationship to the BSA/AML Compliance Officer. You do not perform this review.\r\n\r\nBefore review work begins, confirm the reviewer's independence. Document any conflicts of interest and resolve them before work starts. Unresolved conflicts can invalidate the findings.\r\n\r\nWork with senior management to define the review scope. The scope must match Advanced Compliance Technology, Inc.'s risk level and current service profile. It must cover all of the following:\r\n\r\nAML/CFT policies, procedures, and internal controls\r\nCIP and customer due diligence\r\nOFAC screening and alert disposition\r\nTransaction monitoring and case handling\r\nSAR and CTR filing accuracy and timeliness\r\nRecordkeeping completeness and retention\r\nTraining program adequacy and staff completion\r\nStatus of all prior-cycle findings and remediation\r\n\r\nDuring the review, provide full access to systems, records, and personnel. Restricted access produces incomplete findings.\r\n\r\nThe reviewer delivers the written report directly to senior management. The report does not route through you.\r\n\r\nSenior management assigns an owner and a target completion date for each deficiency. You maintain a remediation log for all open items. Report remediation status at each compliance reporting cycle until every item is closed.\r\n\r\nRetain the review report, supporting workpapers, and remediation records for a minimum of five years. Examiners may request prior-cycle documentation during any examination.\r\n\r\nKeep all program documentation and evidence files examination-ready at all times. Do not assemble documentation in response to an examination notice. The Florida licensing authority examines {{license_type}} licensees at intervals not exceeding five years. Map each review cycle to examiner guidelines. All deficiencies must be remediated before the next scheduled examination."
}