{ "body_html": "

Transaction Monitoring

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You review all transaction activity periodically. This is separate from the daily supervisor review.

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Flag these transactions immediately:

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  1. Single cash transactions between $8,000–$9,999 (sub-CTR alert)
    2. \n
  2. Same-day transactions from one customer totaling $10,000 or more (possible structuring)
    3. \n
  3. Customers cashing more than five checks in any 30-day period
    4. \n
  4. Multiple checks from the same corporate account cashed within one week
    5. \n
  5. Any transaction of $5,000 or more from a first-visit customer
    6. \n
  6. Customers with addresses outside Rapido Facil Exchange Co.'s primary service area
    7. \n
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Also flag these check cashing patterns:

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  1. Sequentially numbered payroll checks from unrelated individuals
    2. \n
  2. Business checks with amounts inconsistent with known payroll cycles or headcount
    3. \n
  3. Government benefit checks presented by third parties claiming power of attorney
    4. \n
  4. Corporate checks without prior workers' compensation verification
    5. \n
  5. Customers who previously failed CIP or were declined and are presenting again
    6. \n
  6. Multiple customers presenting checks from the same employer without a group payroll explanation
    7. \n
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When a supervisor escalates an alert:

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  1. Review transaction history, prior alert records, and CIP documentation.
    2. \n
  2. Conduct open-source inquiry as needed.
    3. \n
  3. Assign one of three dispositions:
    4. \n
\n\n
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  1. Document every disposition. Undocumented dispositions leave no record of resolution.
    2. \n
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Maintain these four records:

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Retain all records for five years. Records not retained for five years cannot be produced during an examination.

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Review all thresholds annually, after significant changes in volume, customer mix, or regulatory guidance. Adjust thresholds outside the annual cycle when the false positive rate exceeds 40% over any 90-day window, or when confirmed-suspicious capture falls below 80% over any 90-day window.

", "narration_text": "You review all transaction activity periodically. This is separate from the daily supervisor review.\r\n\r\nFlag these transactions immediately:\r\n\r\nSingle cash transactions between $8,000–$9,999 (sub-CTR alert)\r\nSame-day transactions from one customer totaling $10,000 or more (possible structuring)\r\nCustomers cashing more than five checks in any 30-day period\r\nMultiple checks from the same corporate account cashed within one week\r\nAny transaction of $5,000 or more from a first-visit customer\r\nCustomers with addresses outside Rapido Facil Exchange Co.'s primary service area\r\n\r\nAlso flag these check cashing patterns:\r\n\r\nSequentially numbered payroll checks from unrelated individuals\r\nBusiness checks with amounts inconsistent with known payroll cycles or headcount\r\nGovernment benefit checks presented by third parties claiming power of attorney\r\nCorporate checks without prior workers' compensation verification\r\nCustomers who previously failed CIP or were declined and are presenting again\r\nMultiple customers presenting checks from the same employer without a group payroll explanation\r\n\r\nWhen a supervisor escalates an alert:\r\n\r\nReview transaction history, prior alert records, and CIP documentation.\r\nConduct open-source inquiry as needed.\r\nAssign one of three dispositions:\r\n - Cleared — no suspicious activity identified\r\n - SAR filed — suspicious activity confirmed; initiate SAR filing and attach the alert record to the case file\r\n - Continued monitoring — inconclusive; flag for 30-day follow-up\r\nDocument every disposition. Undocumented dispositions leave no record of resolution.\r\n\r\nMaintain these four records:\r\n\r\nAlert log — all flagged transactions with triggering parameter, date, disposition, and reviewer identity\r\nInvestigation file — transaction records, CIP copies, and investigation notes\r\nSAR referral log — cross-references alerts with SAR case numbers\r\nThreshold review log — all threshold adjustments with supporting analysis\r\n\r\nRetain all records for five years. Records not retained for five years cannot be produced during an examination.\r\n\r\nReview all thresholds annually, after significant changes in volume, customer mix, or regulatory guidance. Adjust thresholds outside the annual cycle when the false positive rate exceeds 40% over any 90-day window, or when confirmed-suspicious capture falls below 80% over any 90-day window." }