{
  "body_html": "<h2>OFAC Screening and Sanctions Compliance</h2>\n<p>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 the screening result is in hand.</p>\n<p><strong>Confirmed SDN Match</strong></p>\n<p>If screening returns a confirmed match, halt the transaction immediately. Do not return any funds, checks, or documents to the customer. Notify the BSA/AML Compliance Officer within one business hour.</p>\n<p><strong>Prohibited Transaction — No Funds or Documents Held</strong></p>\n<p>If a transaction is prohibited but no funds or documents have been exchanged, decline the transaction. Tell the customer that Advanced Compliance Technology, Inc. cannot process it. Do not say anything beyond that statement. Do not reference OFAC, sanctions lists, or any compliance reason. Notify the BSA/AML Compliance Officer immediately.</p>\n<p><strong>Penalties</strong></p>\n<p>OFAC violations carry serious penalties:</p>\n<ul>\n<li>Civil penalties can reach twice the value of the transaction.</li>\n<li>Criminal penalties include fines up to $1,000,000 and imprisonment up to 20 years per willful violation.</li>\n</ul>\n<p>Every step in this process is mandatory. Do not omit, delay, or modify 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 the screening result is in hand.\r\n\r\nConfirmed SDN Match\r\n\r\nIf screening returns a confirmed match, halt the transaction immediately. Do not return any funds, checks, or documents to the customer. Notify the BSA/AML Compliance Officer within one business hour.\r\n\r\nProhibited Transaction — No Funds or Documents Held\r\n\r\nIf a transaction is prohibited but no funds or documents have been exchanged, decline the transaction. Tell the customer that Advanced Compliance Technology, Inc. cannot process it. Do not say anything beyond that statement. Do not reference OFAC, sanctions lists, or any compliance reason. Notify the BSA/AML Compliance Officer immediately.\r\n\r\nPenalties\r\n\r\nOFAC violations carry serious penalties:\r\n\r\nCivil penalties can reach twice the value of the transaction.\r\nCriminal penalties include fines up to $1,000,000 and imprisonment up to 20 years per willful violation.\r\n\r\nEvery step in this process is mandatory. Do not omit, delay, or modify any of them."
}