{
  "body_html": "<h2>Independent Review</h2>\n<p><strong>Confirm reviewer independence</strong> before work begins. The reviewer must have no reporting relationship to the BSA/AML Compliance Officer. Document any conflicts of interest. Resolve them before the review starts. Unresolved conflicts invalidate the findings.</p>\n<p>Work with senior management to define the <strong>review scope</strong>. The scope must match Rapido Facil Exchange Co.'s risk level and current services. It must cover:</p>\n<ul>\n<li>AML/CFT policies, procedures, and internal controls</li>\n<li>CIP and customer due diligence</li>\n<li>OFAC screening and alert disposition</li>\n<li>Transaction monitoring and case handling</li>\n<li>SAR and CTR filing accuracy and timeliness</li>\n<li>Recordkeeping completeness and retention</li>\n<li>Training program adequacy and staff completion</li>\n<li>Status of all prior-cycle findings and remediation</li>\n</ul>\n<p>During the review, provide full access to systems, records, and personnel. Restricted access produces incomplete findings.</p>\n<p>The reviewer delivers the written report directly to senior management — not through you.</p>\n<p>After the report is delivered:</p>\n<ol>\n<li>Senior management assigns an owner and a <strong>target completion date</strong> for each deficiency.</li>\n<li>Maintain a <strong>remediation log</strong> for all open items.</li>\n<li>Report remediation status at every compliance reporting cycle until all items are closed.</li>\n</ol>\n<p><strong>Retain</strong> the review report, supporting workpapers, and remediation records for a minimum of <strong>five years</strong>. Examiners may request prior-cycle documentation at any examination.</p>\n<p>Keep all documentation <strong>examination-ready at all times</strong>. Do not assemble documentation after receiving an examination notice. The Florida licensing authority examines Part III, Chapter 560, Florida Statutes licensees at intervals not exceeding five years. Map each review cycle to examiner guidelines. All deficiencies must be remediated before the next scheduled examination.</p>",
  "narration_text": "Confirm reviewer independence before work begins. The reviewer must have no reporting relationship to the BSA/AML Compliance Officer. Document any conflicts of interest. Resolve them before the review starts. Unresolved conflicts invalidate the findings.\r\n\r\nWork with senior management to define the review scope. The scope must match Rapido Facil Exchange Co.'s risk level and current services. It must cover:\r\n\r\nAML/CFT policies, procedures, and internal controls\r\nCIP and customer due diligence\r\nOFAC screening and alert disposition\r\nTransaction monitoring and case handling\r\nSAR and CTR filing accuracy and timeliness\r\nRecordkeeping completeness and retention\r\nTraining program adequacy and staff completion\r\nStatus of all prior-cycle findings and remediation\r\n\r\nDuring the review, provide full access to systems, records, and personnel. Restricted access produces incomplete findings.\r\n\r\nThe reviewer delivers the written report directly to senior management — not through you.\r\n\r\nAfter the report is delivered:\r\n\r\nSenior management assigns an owner and a target completion date for each deficiency.\r\nMaintain a remediation log for all open items.\r\nReport remediation status at every compliance reporting cycle until all items are closed.\r\n\r\nRetain the review report, supporting workpapers, and remediation records for a minimum of five years. Examiners may request prior-cycle documentation at any examination.\r\n\r\nKeep all documentation examination-ready at all times. Do not assemble documentation after receiving an examination notice. The Florida licensing authority examines Part III, Chapter 560, Florida Statutes licensees at intervals not exceeding five years. Map each review cycle to examiner guidelines. All deficiencies must be remediated before the next scheduled examination."
}