{
  "body_html": "<h2>Disaster Recovery and Business Continuity</h2>\n<p><strong>CTR filing during outage:</strong></p>\n<ol>\n<li>Get a paper <strong>FinCEN Form 112</strong> from the pre-stored forms at your location.</li>\n<li>Complete it by hand.</li>\n<li>Mail it to the address printed on the form.</li>\n<li>The <strong>15-day deadline does not extend</strong>. A missed deadline is a regulatory violation.</li>\n<li>Log the outage dates, each form mailed, and the mailing date.</li>\n<li>Re-file electronically if FinCEN instructs you to after service is restored.</li>\n</ol>\n<p><strong>SAR filing during outage:</strong></p>\n<ol>\n<li>Get a paper <strong>FinCEN Form 111</strong> from the pre-stored forms at your location.</li>\n<li>Complete it by hand.</li>\n<li>Mail it to the address printed on the form.</li>\n<li>The <strong>30-calendar-day deadline does not extend</strong>. A missed deadline is a regulatory violation.</li>\n<li>Log the outage dates, each form mailed, and the mailing date.</li>\n<li>Re-file electronically if FinCEN instructs you to after service is restored.</li>\n</ol>\n<p><strong>OFAC screening during outage:</strong></p>\n<ol>\n<li>Screen every customer and transaction counterparty against the <strong>SDN List</strong> before processing.</li>\n<li>If internet is available, use OFAC's online search tool.</li>\n<li>If internet is unavailable, use the <strong>downloaded SDN List PDF</strong> stored at your location. Refresh it monthly.</li>\n<li>Do not process any transaction without screening. An unscreened transaction exposes Advanced Compliance Technology, Inc. to federal sanctions liability.</li>\n</ol>\n<p><strong>Transaction monitoring during outage:</strong> A supervisor must manually review transaction logs when the core system is unavailable.</p>\n<p><strong>Customer records:</strong> Access the <strong>encrypted cloud backup</strong> from any authorized, internet-connected device. If internet is unavailable, use the <strong>encrypted USB backup drive</strong> at your location. It contains the prior 24 months of records.</p>\n<p><strong>Check cashing:</strong> Continue cashing checks during a database outage. Enter all backlogged transactions within <strong>2 business days</strong> of system restoration. Missing this window violates Advanced Compliance Technology, Inc.'s Florida state-mandated reporting obligation.</p>\n<p><strong>Your availability:</strong> You must maintain a designated emergency contact number at all times. Keep your phone number, secure email, and alternate contact channel current in the <strong>Business Continuity Plan binder</strong> at each location. Update this information annually.</p>\n<p><strong>If you are unavailable:</strong> Advanced Compliance Technology, Inc. must immediately suspend <strong>check cashing, money transmission, payment instrument sales, foreign currency exchange</strong> operations. Do not allow untrained personnel to perform BSA compliance duties. Operations resume only when you return or a qualified backup is designated and trained. Continuing operations without qualified BSA oversight creates direct regulatory liability.</p>\n<p><strong>Vendor contingency records:</strong> For each BSA-critical vendor, document the compliance function supported, the manual alternative in use during failure, and the outage duration that requires escalation. Update this documentation when any vendor contract is renewed, modified, or terminated.</p>\n<p><strong>Annual testing:</strong> Test all business continuity procedures annually. Each test must simulate at least one BSA-critical system failure. Verify each manual alternative works as documented. Confirm your reachability during the test. Sign a written test record and retain it for <strong>five years</strong>. Remediate all gaps before the next review cycle.</p>",
  "narration_text": "CTR filing during outage:\r\nGet a paper FinCEN Form 112 from the pre-stored forms at your location.\r\nComplete it by hand.\r\nMail it to the address printed on the form.\r\nThe 15-day deadline does not extend. A missed deadline is a regulatory violation.\r\nLog the outage dates, each form mailed, and the mailing date.\r\nRe-file electronically if FinCEN instructs you to after service is restored.\r\n\r\nSAR filing during outage:\r\nGet a paper FinCEN Form 111 from the pre-stored forms at your location.\r\nComplete it by hand.\r\nMail it to the address printed on the form.\r\nThe 30-calendar-day deadline does not extend. A missed deadline is a regulatory violation.\r\nLog the outage dates, each form mailed, and the mailing date.\r\nRe-file electronically if FinCEN instructs you to after service is restored.\r\n\r\nOFAC screening during outage:\r\nScreen every customer and transaction counterparty against the SDN List before processing.\r\nIf internet is available, use OFAC's online search tool.\r\nIf internet is unavailable, use the downloaded SDN List PDF stored at your location. Refresh it monthly.\r\nDo not process any transaction without screening. An unscreened transaction exposes Advanced Compliance Technology, Inc. to federal sanctions liability.\r\n\r\nTransaction monitoring during outage: A supervisor must manually review transaction logs when the core system is unavailable.\r\n\r\nCustomer records: Access the encrypted cloud backup from any authorized, internet-connected device. If internet is unavailable, use the encrypted USB backup drive at your location. It contains the prior 24 months of records.\r\n\r\nCheck cashing: Continue cashing checks during a database outage. Enter all backlogged transactions within 2 business days of system restoration. Missing this window violates Advanced Compliance Technology, Inc.'s Florida state-mandated reporting obligation.\r\n\r\nYour availability: You must maintain a designated emergency contact number at all times. Keep your phone number, secure email, and alternate contact channel current in the Business Continuity Plan binder at each location. Update this information annually.\r\n\r\nIf you are unavailable: Advanced Compliance Technology, Inc. must immediately suspend check cashing, money transmission, payment instrument sales, foreign currency exchange operations. Do not allow untrained personnel to perform BSA compliance duties. Operations resume only when you return or a qualified backup is designated and trained. Continuing operations without qualified BSA oversight creates direct regulatory liability.\r\n\r\nVendor contingency records: For each BSA-critical vendor, document the compliance function supported, the manual alternative in use during failure, and the outage duration that requires escalation. Update this documentation when any vendor contract is renewed, modified, or terminated.\r\n\r\nAnnual testing: Test all business continuity procedures annually. Each test must simulate at least one BSA-critical system failure. Verify each manual alternative works as documented. Confirm your reachability during the test. Sign a written test record and retain it for five years. Remediate all gaps before the next review cycle."
}