{
  "body_html": "<h2>OFAC Screening and Sanctions Compliance</h2>\n<p>Screen every customer against the <strong>Specially Designated Nationals (SDN) List</strong> before every transaction. You must complete this step before you accept any check. You must complete it before you disburse any cash. Do not begin the transaction until you have the screening result.</p>\n<p><strong>If screening returns a confirmed SDN match:</strong></p>\n<ol>\n<li>Halt the transaction immediately.</li>\n<li>Do not return any funds, checks, or documents to the customer.</li>\n<li>Notify the BSA/AML Compliance Officer within one business hour.</li>\n</ol>\n<p><strong>If a transaction is prohibited and no funds or documents have been exchanged:</strong></p>\n<ol>\n<li>Decline the transaction.</li>\n<li>Tell the customer that Advanced Compliance Technology, Inc. cannot process it.</li>\n<li>Do not say anything beyond that statement. Do not mention OFAC, sanctions lists, or any compliance reason.</li>\n<li>Notify the BSA/AML Compliance Officer immediately.</li>\n</ol>\n<p><strong>Penalties</strong></p>\n<p>OFAC violations carry serious penalties. Civil penalties can reach twice the transaction amount. Criminal penalties include fines up to $1,000,000 and imprisonment up to 20 years per willful violation.</p>\n<p>Every step is mandatory. Do not skip, delay, or change any of them.</p>",
  "narration_text": "Screen every customer against the Specially Designated Nationals (SDN) List before every transaction. You must complete this step before you accept any check. You must complete it before you disburse any cash. Do not begin the transaction until you have the screening result.\r\n\r\nIf screening returns a confirmed SDN match:\r\n\r\nHalt the transaction immediately.\r\nDo not return any funds, checks, or documents to the customer.\r\nNotify the BSA/AML Compliance Officer within one business hour.\r\n\r\nIf a transaction is prohibited and no funds or documents have been exchanged:\r\n\r\nDecline the transaction.\r\nTell the customer that Advanced Compliance Technology, Inc. cannot process it.\r\nDo not say anything beyond that statement. Do not mention OFAC, sanctions lists, or any compliance reason.\r\nNotify the BSA/AML Compliance Officer immediately.\r\n\r\nPenalties\r\n\r\nOFAC violations carry serious penalties. Civil penalties can reach twice the transaction amount. Criminal penalties include fines up to $1,000,000 and imprisonment up to 20 years per willful violation.\r\n\r\nEvery step is mandatory. Do not skip, delay, or change any of them."
}