{
  "body_html": "<h2>Customer and Account Closure</h2>\n<p>Before closing any customer account, you must complete these steps in order. Do not skip any step.</p>\n<p><strong>Step 1: File a SAR if suspicious activity was involved</strong> A SAR is a government form you file when something about an account looks illegal. If this account had suspicious activity, file the SAR before you do anything else. Write the SAR reference number in the case file.</p>\n<p><strong>Step 2: Check the 314(a) list</strong> The government sometimes sends a list of names connected to investigations. This is called a 314(a) search. Confirm this customer is not on that list. If they are, stop immediately and follow Section 18 before proceeding.</p>\n<p><strong>Step 3: Check for an OFAC block</strong> OFAC is a government agency that can legally freeze certain accounts. If this account is blocked, you cannot process a normal closure. You must move the funds to a separate interest-bearing account. You must file a blocking report with OFAC within 10 business days. The account must stay open and restricted until OFAC gives written authorization to close it.</p>\n<p><strong>Step 4: Secure all records</strong> All transaction records, ID documents, and account files must be preserved for the full required retention period. Closing the account does not reduce this obligation.</p>\n<p><strong>Step 5: Review what you communicate to the customer</strong> You must not mention a SAR, suspicious activity, a law enforcement inquiry, or any investigation. Disclosing this information is called tipping off — it is a federal crime. The only permissible explanation is that Rapido Facil Exchange Co. has made a business decision to end the relationship.</p>\n<p><strong>Step 6: Execute and document the closure</strong> Process the closure using business decision language only. Record the compliance basis, closure date, SAR reference if applicable, and fund disposition in the case file.</p>",
  "narration_text": "Before closing any customer account, you must complete these steps in order. Do not skip any step.\r\n\r\nStep 1: File a SAR if suspicious activity was involved\r\nA SAR is a government form you file when something about an account looks illegal. If this account had suspicious activity, file the SAR before you do anything else. Write the SAR reference number in the case file.\r\n\r\nStep 2: Check the 314(a) list\r\nThe government sometimes sends a list of names connected to investigations. This is called a 314(a) search. Confirm this customer is not on that list. If they are, stop immediately and follow Section 18 before proceeding.\r\n\r\nStep 3: Check for an OFAC block\r\nOFAC is a government agency that can legally freeze certain accounts. If this account is blocked, you cannot process a normal closure. You must move the funds to a separate interest-bearing account. You must file a blocking report with OFAC within 10 business days. The account must stay open and restricted until OFAC gives written authorization to close it.\r\n\r\nStep 4: Secure all records\r\nAll transaction records, ID documents, and account files must be preserved for the full required retention period. Closing the account does not reduce this obligation.\r\n\r\nStep 5: Review what you communicate to the customer\r\nYou must not mention a SAR, suspicious activity, a law enforcement inquiry, or any investigation. Disclosing this information is called tipping off — it is a federal crime. The only permissible explanation is that Rapido Facil Exchange Co. has made a business decision to end the relationship.\r\n\r\nStep 6: Execute and document the closure\r\nProcess the closure using business decision language only. Record the compliance basis, closure date, SAR reference if applicable, and fund disposition in the case file."
}