The owner of Rapido Facil Exchange Co. has formally approved this AML/CFT compliance program. A corporate resolution records this approval. Maintain that resolution in the compliance files. Update it each time the program is revised. Current records confirm the program reflects active requirements.
\nThe resolution establishes the BSA/AML Compliance Officer position. It grants you authority to implement, maintain, and enforce all program components. You report directly to the owner. You may raise compliance concerns to the owner without restriction.
\nYou must have access to regulatory reference materials, training resources, and personnel time for AML/CFT functions. When an operational decision creates compliance risk, the owner must submit it to you before implementation. Pre-implementation review prevents violations from being built into business operations.
\nReport to the owner no less than quarterly. Each report must address:
\nDocument each report and retain it in the compliance files. Documentation creates the audit trail examiners expect.
\nWhen a deficiency is identified, escalate it to the owner within five business days. This applies whether the deficiency comes from internal review, independent audit, or regulatory examination. You and the owner then jointly establish a remediation timeline with assigned accountability. Prompt escalation prevents a known gap from becoming an unaddressed violation.
\nTrack every open deficiency until it is closed. Report open deficiency status in each quarterly briefing. Continuous tracking ensures no item lapses without resolution.
", "narration_text": "The owner of Rapido Facil Exchange Co. has formally approved this AML/CFT compliance program. A corporate resolution records this approval. Maintain that resolution in the compliance files. Update it each time the program is revised. Current records confirm the program reflects active requirements.\r\n\r\nThe resolution establishes the BSA/AML Compliance Officer position. It grants you authority to implement, maintain, and enforce all program components. You report directly to the owner. You may raise compliance concerns to the owner without restriction.\r\n\r\nYou must have access to regulatory reference materials, training resources, and personnel time for AML/CFT functions. When an operational decision creates compliance risk, the owner must submit it to you before implementation. Pre-implementation review prevents violations from being built into business operations.\r\n\r\nReport to the owner no less than quarterly. Each report must address:\r\n\r\nProgram status and any material changes\r\nSignificant compliance events, including SARs filed, CTRs filed, and OFAC matches\r\nResults of transaction monitoring reviews\r\nExamination findings and regulatory correspondence\r\nStatus of any open remediation items\r\n\r\nDocument each report and retain it in the compliance files. Documentation creates the audit trail examiners expect.\r\n\r\nWhen a deficiency is identified, escalate it to the owner within five business days. This applies whether the deficiency comes from internal review, independent audit, or regulatory examination. You and the owner then jointly establish a remediation timeline with assigned accountability. Prompt escalation prevents a known gap from becoming an unaddressed violation.\r\n\r\nTrack every open deficiency until it is closed. Report open deficiency status in each quarterly briefing. Continuous tracking ensures no item lapses without resolution." }