{
  "body_html": "<h2>Customer and Account Closure</h2>\n<p>When Rapido Facil Exchange Co. closes a customer relationship for compliance reasons, these procedures apply without exception.</p>\n<p><strong>SAR Priority</strong></p>\n<p>If suspicious activity is involved, you must file a SAR before beginning the closure process. When the closure decision and the SAR determination arise at the same time, you complete the SAR first. No closure action begins until the SAR is filed. This prevents a closure from functioning as evasion of a required federal report.</p>\n<p><strong>OFAC-Blocked Accounts</strong></p>\n<p>Standard closure procedures do not apply when an account or transaction is subject to an OFAC blocking order. You hold blocked funds in a segregated, interest-bearing account. You file a blocking report with OFAC within 10 business days of the blocking action. You manage all subsequent OFAC correspondence for that account. The account remains open and restricted until OFAC authorizes disposition in writing. This preserves the legal status of funds that federal law prohibits you from releasing or returning.</p>\n<p><strong>314(a) Verification</strong></p>\n<p>Before executing any compliance-driven closure, you confirm that no active FinCEN 314(a) search covers the customer. If a 314(a) match exists, you pause the closure immediately and follow Section 18. This prevents a closure from disrupting an active law enforcement information request.</p>\n<p><strong>Closure Communications</strong></p>\n<p>You review all compliance-driven closure communications before delivery. Permissible communications state only that Rapido Facil Exchange Co. has made a business decision to end the relationship. The following content is prohibited in any closure communication, written or verbal:</p>\n<ul>\n<li>Reference to a SAR filing or any suspicious activity report</li>\n<li>Reference to a law enforcement inquiry, subpoena, or investigation</li>\n<li>Any language indicating that the closure basis is suspicious activity or unusual transactions</li>\n<li>Any language that could alert the customer to the nature of the compliance concern</li>\n</ul>\n<p>Disclosing a SAR or its basis constitutes unlawful tipping off. Violations carry federal criminal liability.</p>\n<p><strong>Record Retention</strong></p>\n<p>Closure does not reduce, modify, or accelerate any record retention obligation. You retain all transaction records, identification documents, and account files for the full required retention period regardless of closure status. This satisfies federal examination requirements no matter when the customer relationship ended.</p>\n<p><strong>Closure Procedure</strong></p>\n<ol>\n<li><strong>Evaluate</strong> — Document the compliance basis for closure in the case file.</li>\n<li><strong>SAR review</strong> — If suspicious activity is involved, file the SAR on FinCEN Form 111 first. Record the SAR filing reference internally before proceeding.</li>\n<li><strong>314(a) check</strong> — Confirm no active 314(a) search covers the customer. If a match exists, pause closure and follow Section 18.</li>\n<li><strong>OFAC check</strong> — Confirm the account is not subject to a blocking order. If blocked, halt standard closure and follow the OFAC blocking protocol.</li>\n<li><strong>Secure records</strong> — Confirm all records are preserved for the full retention period.</li>\n<li><strong>Draft communication</strong> — Review the closure communication. Remove any prohibited content before delivery.</li>\n<li><strong>Execute closure</strong> — Process closure using business decision language only.</li>\n<li><strong>Document</strong> — Record the closure date, internal basis, SAR filing reference if applicable, and fund disposition.</li>\n</ol>",
  "narration_text": "When Rapido Facil Exchange Co. closes a customer relationship for compliance reasons, these procedures apply without exception.\r\n\r\nSAR Priority\r\n\r\nIf suspicious activity is involved, you must file a SAR before beginning the closure process. When the closure decision and the SAR determination arise at the same time, you complete the SAR first. No closure action begins until the SAR is filed. This prevents a closure from functioning as evasion of a required federal report.\r\n\r\nOFAC-Blocked Accounts\r\n\r\nStandard closure procedures do not apply when an account or transaction is subject to an OFAC blocking order. You hold blocked funds in a segregated, interest-bearing account. You file a blocking report with OFAC within 10 business days of the blocking action. You manage all subsequent OFAC correspondence for that account. The account remains open and restricted until OFAC authorizes disposition in writing. This preserves the legal status of funds that federal law prohibits you from releasing or returning.\r\n\r\n314(a) Verification\r\n\r\nBefore executing any compliance-driven closure, you confirm that no active FinCEN 314(a) search covers the customer. If a 314(a) match exists, you pause the closure immediately and follow Section 18. This prevents a closure from disrupting an active law enforcement information request.\r\n\r\nClosure Communications\r\n\r\nYou review all compliance-driven closure communications before delivery. Permissible communications state only that Rapido Facil Exchange Co. has made a business decision to end the relationship. The following content is prohibited in any closure communication, written or verbal:\r\n\r\nReference to a SAR filing or any suspicious activity report\r\nReference to a law enforcement inquiry, subpoena, or investigation\r\nAny language indicating that the closure basis is suspicious activity or unusual transactions\r\nAny language that could alert the customer to the nature of the compliance concern\r\n\r\nDisclosing a SAR or its basis constitutes unlawful tipping off. Violations carry federal criminal liability.\r\n\r\nRecord Retention\r\n\r\nClosure does not reduce, modify, or accelerate any record retention obligation. You retain all transaction records, identification documents, and account files for the full required retention period regardless of closure status. This satisfies federal examination requirements no matter when the customer relationship ended.\r\n\r\nClosure Procedure\r\n\r\nEvaluate — Document the compliance basis for closure in the case file.\r\nSAR review — If suspicious activity is involved, file the SAR on FinCEN Form 111 first. Record the SAR filing reference internally before proceeding.\r\n314(a) check — Confirm no active 314(a) search covers the customer. If a match exists, pause closure and follow Section 18.\r\nOFAC check — Confirm the account is not subject to a blocking order. If blocked, halt standard closure and follow the OFAC blocking protocol.\r\nSecure records — Confirm all records are preserved for the full retention period.\r\nDraft communication — Review the closure communication. Remove any prohibited content before delivery.\r\nExecute closure — Process closure using business decision language only.\r\nDocument — Record the closure date, internal basis, SAR filing reference if applicable, and fund disposition."
}