{
  "body_html": "<h2>Independent Review</h2>\n<p>Rapido Facil Exchange Co. maintains an independent review of its AML/CFT program. The BSA/AML Compliance Officer does not perform this review. The reviewer must have no operational reporting relationship to the BSA/AML Compliance Officer. This independence ensures findings are objective and free from influence over the functions being reviewed.</p>\n<p>Before engaging a reviewer, the BSA/AML Compliance Officer confirms the reviewer's independence. Conflicts of interest must be documented and resolved before review work begins. Unresolved conflicts can invalidate findings and expose the program to examination criticism.</p>\n<p>The BSA/AML Compliance Officer participates in defining the review scope with senior management. The scope must be commensurate with Rapido Facil Exchange Co.'s risk level and current service profile. The scope must cover all core program elements:</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, the BSA/AML Compliance Officer provides full access to systems, records, and personnel. Restricted access produces incomplete findings and weakens the program's defensibility.</p>\n<p>The reviewer delivers a written report directly to senior management. The report does not route through the BSA/AML Compliance Officer. Direct reporting to senior management preserves the independence of the review function.</p>\n<p>Senior management assigns an owner and a target completion date for each identified deficiency. The BSA/AML Compliance Officer maintains a remediation log for all open items. The BSA/AML Compliance Officer reports remediation status at each compliance reporting cycle until every item is closed. A complete remediation log demonstrates that Rapido Facil Exchange Co. responds to findings systematically.</p>\n<p>The BSA/AML Compliance Officer retains the review report, supporting workpapers, and remediation records for a minimum of five years. Examiners may request prior-cycle documentation during any examination.</p>\n<p>The BSA/AML Compliance Officer maintains program documentation and evidence files in examination-ready condition at all times. Documentation must not be assembled in response to an examination notice. The Florida licensing authority examines Part III, Chapter 560, Florida Statutes licensees at intervals not exceeding five years. The BSA/AML Compliance Officer maps each review cycle to examiner guidelines. All deficiencies must be remediated before the next scheduled examination.</p>",
  "narration_text": "Rapido Facil Exchange Co. maintains an independent review of its AML/CFT program. The BSA/AML Compliance Officer does not perform this review. The reviewer must have no operational reporting relationship to the BSA/AML Compliance Officer. This independence ensures findings are objective and free from influence over the functions being reviewed.\r\n\r\nBefore engaging a reviewer, the BSA/AML Compliance Officer confirms the reviewer's independence. Conflicts of interest must be documented and resolved before review work begins. Unresolved conflicts can invalidate findings and expose the program to examination criticism.\r\n\r\nThe BSA/AML Compliance Officer participates in defining the review scope with senior management. The scope must be commensurate with Rapido Facil Exchange Co.'s risk level and current service profile. The scope must cover all core program elements:\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, the BSA/AML Compliance Officer provides full access to systems, records, and personnel. Restricted access produces incomplete findings and weakens the program's defensibility.\r\n\r\nThe reviewer delivers a written report directly to senior management. The report does not route through the BSA/AML Compliance Officer. Direct reporting to senior management preserves the independence of the review function.\r\n\r\nSenior management assigns an owner and a target completion date for each identified deficiency. The BSA/AML Compliance Officer maintains a remediation log for all open items. The BSA/AML Compliance Officer reports remediation status at each compliance reporting cycle until every item is closed. A complete remediation log demonstrates that Rapido Facil Exchange Co. responds to findings systematically.\r\n\r\nThe BSA/AML Compliance Officer retains the review report, supporting workpapers, and remediation records for a minimum of five years. Examiners may request prior-cycle documentation during any examination.\r\n\r\nThe BSA/AML Compliance Officer maintains program documentation and evidence files in examination-ready condition at all times. Documentation must not be assembled in response to an examination notice. The Florida licensing authority examines Part III, Chapter 560, Florida Statutes licensees at intervals not exceeding five years. The BSA/AML Compliance Officer maps each review cycle to examiner guidelines. All deficiencies must be remediated before the next scheduled examination."
}