{
  "body_html": "<h2>Information Sharing</h2>\n<p>You are the BSA/AML Compliance Officer. You own every step of the 314(a) process.</p>\n<p>When a 314(a) request arrives from FinCEN, retrieve the subject list immediately. The response window is typically two weeks from the issuance date. Do not wait.</p>\n<p>Search all customer records, transaction records, and account files. Match each subject by name, address, and identification number. Apply the date range specified in the request. Search everything — a missed match is a compliance failure.</p>\n<p>If you find a match, submit a positive match response to FinCEN within the required timeframe. A 314(a) match response does not replace a SAR obligation. If the facts independently require a SAR, file it separately.</p>\n<p>Document every search in the compliance file. Record the search date, the scope of records searched, and the names of all personnel who conducted the search. Record both positive and negative results.</p>\n<p>314(a) information is strictly confidential. The request itself is confidential. Subject identities are confidential. All search results are confidential. Do not disclose any of this to customers, front-line staff, uninvolved employees, or third parties. Unauthorized disclosure can compromise an active law enforcement investigation.</p>\n<p>Rapido Facil Exchange Co. does not currently participate in the voluntary 314(b) program. You must evaluate participation if transaction volume, customer base, or risk profile changes in a way that would benefit from inter-institutional sharing.</p>",
  "narration_text": "You are the BSA/AML Compliance Officer. You own every step of the 314(a) process.\r\n\r\nWhen a 314(a) request arrives from FinCEN, retrieve the subject list immediately. The response window is typically two weeks from the issuance date. Do not wait.\r\n\r\nSearch all customer records, transaction records, and account files. Match each subject by name, address, and identification number. Apply the date range specified in the request. Search everything — a missed match is a compliance failure.\r\n\r\nIf you find a match, submit a positive match response to FinCEN within the required timeframe. A 314(a) match response does not replace a SAR obligation. If the facts independently require a SAR, file it separately.\r\n\r\nDocument every search in the compliance file. Record the search date, the scope of records searched, and the names of all personnel who conducted the search. Record both positive and negative results.\r\n\r\n314(a) information is strictly confidential. The request itself is confidential. Subject identities are confidential. All search results are confidential. Do not disclose any of this to customers, front-line staff, uninvolved employees, or third parties. Unauthorized disclosure can compromise an active law enforcement investigation.\r\n\r\nRapido Facil Exchange Co. does not currently participate in the voluntary 314(b) program. You must evaluate participation if transaction volume, customer base, or risk profile changes in a way that would benefit from inter-institutional sharing."
}