{
  "body_html": "<h2>Information Sharing</h2>\n<p>The BSA/AML Compliance Officer receives, processes, and responds to all 314(a) information requests from FinCEN. Rapido Facil Exchange Co. must comply fully with every request.</p>\n<p>Upon receipt of a request, obtain the subject list from FinCEN within the specified response window. The response window is typically two weeks from the issuance date. Obtaining the list promptly preserves the full time available to complete the search.</p>\n<p>Search all customer records, transaction records, and account files maintained by Rapido Facil Exchange Co.. Match each subject by name, address, and identification number. Apply the date range specified in the request. A complete search reduces the risk of an undetected positive match.</p>\n<p>If the search identifies a match, submit a positive match response to FinCEN within the required timeframe. Timely reporting gives FinCEN complete information while the investigation is active. A 314(a) match response does not replace any SAR obligation that independently arises from the same facts. File a SAR separately if the facts require one.</p>\n<p>Record the following in the compliance file: the search date, the scope of records searched, and the names of personnel who conducted the search. Record both positive and negative results. A complete record demonstrates that the search was performed and supports examination readiness.</p>\n<p>The existence of a 314(a) request is strictly confidential. The identities of named subjects are strictly confidential. All search results are strictly confidential. Do not disclose any of this information to customers, uninvolved employees, or third parties. Do not inform front-line staff of subject identities. Unauthorized disclosure can compromise a law enforcement investigation.</p>\n<p>Rapido Facil Exchange Co. does not currently participate in the voluntary 314(b) information sharing program. The BSA/AML Compliance Officer must evaluate participation if transaction volume, customer base, or risk profile changes in a manner that would benefit from inter-institutional sharing.</p>",
  "narration_text": "The BSA/AML Compliance Officer receives, processes, and responds to all 314(a) information requests from FinCEN. Rapido Facil Exchange Co. must comply fully with every request.\r\n\r\nUpon receipt of a request, obtain the subject list from FinCEN within the specified response window. The response window is typically two weeks from the issuance date. Obtaining the list promptly preserves the full time available to complete the search.\r\n\r\nSearch all customer records, transaction records, and account files maintained by Rapido Facil Exchange Co.. Match each subject by name, address, and identification number. Apply the date range specified in the request. A complete search reduces the risk of an undetected positive match.\r\n\r\nIf the search identifies a match, submit a positive match response to FinCEN within the required timeframe. Timely reporting gives FinCEN complete information while the investigation is active. A 314(a) match response does not replace any SAR obligation that independently arises from the same facts. File a SAR separately if the facts require one.\r\n\r\nRecord the following in the compliance file: the search date, the scope of records searched, and the names of personnel who conducted the search. Record both positive and negative results. A complete record demonstrates that the search was performed and supports examination readiness.\r\n\r\nThe existence of a 314(a) request is strictly confidential. The identities of named subjects are strictly confidential. All search results are strictly confidential. Do not disclose any of this information to customers, uninvolved employees, or third parties. Do not inform front-line staff of subject identities. Unauthorized disclosure can compromise a law enforcement investigation.\r\n\r\nRapido Facil Exchange Co. does not currently participate in the voluntary 314(b) information sharing program. The BSA/AML Compliance Officer must evaluate participation if transaction volume, customer base, or risk profile changes in a manner that would benefit from inter-institutional sharing."
}