{
  "body_html": "<h2>Disaster Recovery and Business Continuity</h2>\n<p>When our computer systems go down, compliance work does not stop.</p>\n<p><strong>Reporting forms:</strong> We keep paper copies of two forms on site. To report a large cash transaction, use <strong>FinCEN Form 112</strong>. To report suspicious activity, use <strong>FinCEN Form 111</strong>. Fill the form out by hand and mail it to the address printed on the form. CTR forms must be filed within 15 days. SAR forms must be filed within 30 days. These deadlines do not change during an outage. Missing a deadline is a regulatory violation.</p>\n<p><strong>OFAC screening:</strong> Before processing any transaction, you must check the customer against the OFAC SDN List — a federal list of people and companies we are not allowed to do business with. If the internet is available, use OFAC's online search tool. If the internet is down, use the downloaded SDN List PDF stored at your location. You must never skip this step. Processing an unscreened transaction exposes Advanced Compliance Technology, Inc. to federal sanctions liability.</p>\n<p><strong>Transaction monitoring:</strong> When systems are down, a supervisor must manually review transaction logs.</p>\n<p><strong>Customer records:</strong> Use the encrypted cloud backup if you have internet access. If not, use the encrypted USB backup drive stored at your location.</p>\n<p><strong>Check cashing:</strong> Continue cashing checks during an outage. Enter all transactions into the system within 2 business days after it is restored. Missing this window violates Advanced Compliance Technology, Inc.'s Florida state-mandated reporting obligation.</p>\n<p><strong>Your availability:</strong> Keep your phone number, email, and backup contact current in the Business Continuity Plan binder at each location. If you are unreachable, Advanced Compliance Technology, Inc. must immediately suspend check cashing, money transmission, payment instrument sales, foreign currency exchange operations. Do not allow untrained employees to perform BSA compliance duties.</p>",
  "narration_text": "When our computer systems go down, compliance work does not stop.\r\n\r\nReporting forms: We keep paper copies of two forms on site. To report a large cash transaction, use FinCEN Form 112. To report suspicious activity, use FinCEN Form 111. Fill the form out by hand and mail it to the address printed on the form. CTR forms must be filed within 15 days. SAR forms must be filed within 30 days. These deadlines do not change during an outage. Missing a deadline is a regulatory violation.\r\n\r\nOFAC screening: Before processing any transaction, you must check the customer against the OFAC SDN List — a federal list of people and companies we are not allowed to do business with. If the internet is available, use OFAC's online search tool. If the internet is down, use the downloaded SDN List PDF stored at your location. You must never skip this step. Processing an unscreened transaction exposes Advanced Compliance Technology, Inc. to federal sanctions liability.\r\n\r\nTransaction monitoring: When systems are down, a supervisor must manually review transaction logs.\r\n\r\nCustomer records: Use the encrypted cloud backup if you have internet access. If not, use the encrypted USB backup drive stored at your location.\r\n\r\nCheck cashing: Continue cashing checks during an outage. Enter all transactions into the system within 2 business days after it is restored. Missing this window violates Advanced Compliance Technology, Inc.'s Florida state-mandated reporting obligation.\r\n\r\nYour availability: Keep your phone number, email, and backup contact current in the Business Continuity Plan binder at each location. If you are unreachable, Advanced Compliance Technology, Inc. must immediately suspend check cashing, money transmission, payment instrument sales, foreign currency exchange operations. Do not allow untrained employees to perform BSA compliance duties."
}