{
  "body_html": "<h2>Board/Owner Oversight and Governance</h2>\n<p>The owner of Advanced Compliance Technology, Inc. has formally approved this AML/CFT compliance program. A corporate resolution documents this approval. Keep that resolution in the compliance files. Update it each time the program changes.</p>\n<p>The resolution establishes the BSA/AML Compliance Officer position. Your authority covers implementing, maintaining, and enforcing all program components. You report directly to the owner. You may raise compliance concerns to the owner without restriction.</p>\n<p>You must have access to regulatory reference materials, training resources, and personnel time for AML/CFT functions. Any operational decision that creates compliance risk must be submitted to you before implementation.</p>\n<p>Report to the owner no less than quarterly. Each report must cover:</p>\n<ul>\n<li>Program status and any material changes</li>\n<li>Significant compliance events — SARs filed, CTRs filed, and OFAC matches</li>\n<li>Transaction monitoring review results</li>\n<li>Examination findings and regulatory correspondence</li>\n<li>Status of all open remediation items</li>\n</ul>\n<p>Document each report. Retain it in the compliance files.</p>\n<p>When you identify a deficiency, escalate it to the owner within five business days. This applies to deficiencies from internal review, independent audit, or regulatory examination. You and the owner jointly set a remediation timeline with assigned accountability.</p>\n<p>Track every open deficiency until it is closed. Include open deficiency status in every quarterly report.</p>",
  "narration_text": "The owner of Advanced Compliance Technology, Inc. has formally approved this AML/CFT compliance program. A corporate resolution documents this approval. Keep that resolution in the compliance files. Update it each time the program changes.\r\n\r\nThe resolution establishes the BSA/AML Compliance Officer position. Your authority covers implementing, maintaining, and enforcing all program components. You report directly to the owner. You may raise compliance concerns to the owner without restriction.\r\n\r\nYou must have access to regulatory reference materials, training resources, and personnel time for AML/CFT functions. Any operational decision that creates compliance risk must be submitted to you before implementation.\r\n\r\nReport to the owner no less than quarterly. Each report must cover:\r\n\r\nProgram status and any material changes\r\nSignificant compliance events — SARs filed, CTRs filed, and OFAC matches\r\nTransaction monitoring review results\r\nExamination findings and regulatory correspondence\r\nStatus of all open remediation items\r\n\r\nDocument each report. Retain it in the compliance files.\r\n\r\nWhen you identify a deficiency, escalate it to the owner within five business days. This applies to deficiencies from internal review, independent audit, or regulatory examination. You and the owner jointly set a remediation timeline with assigned accountability.\r\n\r\nTrack every open deficiency until it is closed. Include open deficiency status in every quarterly report."
}