{
  "body_html": "<h2>AML/CFT Compliance Officer</h2>\n<p>You are the BSA/AML Compliance Officer for Rapido Facil Exchange Co.. You run the AML/CFT program day to day.</p>\n<p><strong>Reports and Records</strong></p>\n<ol>\n<li>File all <strong>Currency Transaction Reports</strong>, <strong>Suspicious Activity Reports</strong>, and <strong>Currency and Monetary Instrument Reports</strong> accurately and on time.</li>\n<li>Maintain all records required by federal regulation.</li>\n</ol>\n<p><strong>Policies and Training</strong></p>\n<ol>\n<li>Design, update, and enforce Rapido Facil Exchange Co.'s AML/CFT policies and procedures.</li>\n<li>Deliver <strong>annual AML training</strong> to all applicable personnel.</li>\n</ol>\n<p><strong>Transaction Monitoring</strong></p>\n<ol>\n<li>Monitor transactions for suspicious activity.</li>\n<li>Manage the <strong>SAR determination and filing process</strong>.</li>\n<li>Halt or suspend any transaction suspected of involving money laundering, terrorist financing, or sanctions violations. Keep it suspended pending investigation.</li>\n</ol>\n<p><strong>Regulatory Contact</strong></p>\n<ol>\n<li>Serve as the primary contact for regulatory examinations, law enforcement inquiries, and FinCEN communications.</li>\n</ol>\n<p><strong>Reporting Up</strong></p>\n<ol>\n<li>Provide compliance status updates to the owner or principal <strong>at least quarterly</strong>.</li>\n<li>Report any material compliance incident to the owner or principal <strong>immediately</strong>.</li>\n</ol>\n<p><strong>What You Cannot Do</strong> You must not conduct Rapido Facil Exchange Co.'s independent review of the AML/CFT program. A qualified external reviewer or an internal party with no operational compliance responsibilities must perform that function.</p>\n<p><strong>If You Are Absent</strong> There is no designated backup BSA/AML Compliance Officer. If you are unavailable for an extended period, Rapido Facil Exchange Co. must suspend check cashing operations.</p>\n<p><strong>Hiring</strong></p>\n<ol>\n<li>Before any offer of employment, run a <strong>criminal background check</strong> covering at least seven years.</li>\n<li>Automatically disqualify applicants with convictions for financial crimes, fraud, theft, or money laundering.</li>\n<li>Verify each applicant's identity, employment history, and professional references.</li>\n<li>Screen every applicant against the <strong>OFAC Specially Designated Nationals list</strong> before making an offer.</li>\n</ol>\n<p><strong>Employee Integrity</strong></p>\n<ul>\n<li>Employees with transaction-processing or compliance responsibilities must report personal financial difficulties, unusual personal financial activity, and outside employment that could create a conflict of interest.</li>\n<li>Employees must not process transactions for personal acquaintances outside standard procedures without supervisor approval.</li>\n<li>You must enforce both requirements.</li>\n</ul>\n<p><strong>Violations</strong> An employee who deliberately bypasses AML/CFT controls faces <strong>immediate suspension</strong> and <strong>termination</strong> upon a finding of cause. The same applies to any employee who helped a customer structure transactions or failed to report known suspicious activity. You must report confirmed violations to the owner or principal and, where legally required, to the appropriate regulatory authority.</p>",
  "narration_text": "You are the BSA/AML Compliance Officer for Rapido Facil Exchange Co.. You run the AML/CFT program day to day.\r\n\r\nReports and Records\r\nFile all Currency Transaction Reports, Suspicious Activity Reports, and Currency and Monetary Instrument Reports accurately and on time.\r\nMaintain all records required by federal regulation.\r\n\r\nPolicies and Training\r\nDesign, update, and enforce Rapido Facil Exchange Co.'s AML/CFT policies and procedures.\r\nDeliver annual AML training to all applicable personnel.\r\n\r\nTransaction Monitoring\r\nMonitor transactions for suspicious activity.\r\nManage the SAR determination and filing process.\r\nHalt or suspend any transaction suspected of involving money laundering, terrorist financing, or sanctions violations. Keep it suspended pending investigation.\r\n\r\nRegulatory Contact\r\nServe as the primary contact for regulatory examinations, law enforcement inquiries, and FinCEN communications.\r\n\r\nReporting Up\r\nProvide compliance status updates to the owner or principal at least quarterly.\r\nReport any material compliance incident to the owner or principal immediately.\r\n\r\nWhat You Cannot Do\r\nYou must not conduct Rapido Facil Exchange Co.'s independent review of the AML/CFT program. A qualified external reviewer or an internal party with no operational compliance responsibilities must perform that function.\r\n\r\nIf You Are Absent\r\nThere is no designated backup BSA/AML Compliance Officer. If you are unavailable for an extended period, Rapido Facil Exchange Co. must suspend check cashing operations.\r\n\r\nHiring\r\nBefore any offer of employment, run a criminal background check covering at least seven years.\r\nAutomatically disqualify applicants with convictions for financial crimes, fraud, theft, or money laundering.\r\nVerify each applicant's identity, employment history, and professional references.\r\nScreen every applicant against the OFAC Specially Designated Nationals list before making an offer.\r\n\r\nEmployee Integrity\r\nEmployees with transaction-processing or compliance responsibilities must report personal financial difficulties, unusual personal financial activity, and outside employment that could create a conflict of interest.\r\nEmployees must not process transactions for personal acquaintances outside standard procedures without supervisor approval.\r\nYou must enforce both requirements.\r\n\r\nViolations\r\nAn employee who deliberately bypasses AML/CFT controls faces immediate suspension and termination upon a finding of cause. The same applies to any employee who helped a customer structure transactions or failed to report known suspicious activity. You must report confirmed violations to the owner or principal and, where legally required, to the appropriate regulatory authority."
}