{ "body_html": "

Responding to Law Enforcement and Legal Process

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You are Rapido Facil Exchange Co.'s sole point of contact for all law enforcement requests, subpoenas, and legal process. Staff who receive any law enforcement contact must route it to you immediately — without responding.

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When any law enforcement contact arrives:

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  1. Log it immediately. Record: date received, requesting agency and officer, contact method, stated scope, response deadline, and disposition.
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  2. Keep the log restricted. Tellers and customer-facing staff must not have access.
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When a subpoena arrives:

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  1. Verify it is facially valid: proper court or agency caption, authorized signature, and a return date.
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  2. Notify counsel if the return date is fewer than 10 business days away or if the scope is ambiguous.
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  3. Search all records systems for responsive materials — transaction files, CIP records, identification copies, and monitoring logs.
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  4. Compile responsive documents. Do not include any SAR or SAR-related information.
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  5. Produce documents by the return date. Retain copies of all produced materials. Log the completed response.
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When a National Security Letter (NSL) arrives:

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  1. Escalate to counsel immediately — before any other action.
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  2. Do not discuss receipt of the NSL with any employee beyond those required to respond.
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  3. Comply with all record production requirements within the specified timeframe.
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  4. Document the NSL in a secure, segregated log accessible only to you and counsel.
    5. \n
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SAR confidentiality — always:

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When a verbal law enforcement request arrives:

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  1. Log it immediately. Record the officer's name, agency, and badge number if provided.
    2. \n
  2. Do not produce any records or customer information. A written request or subpoena is required first.
    3. \n
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Confidentiality: Do not disclose to any customer or third party that a request, subpoena, or NSL has been received. Disclosure is permitted only upon written advice of counsel.

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Retention: Retain all law enforcement request documentation for a minimum of five years. This includes the original request, Rapido Facil Exchange Co.'s response, copies of all produced records, and all related correspondence. Store in a secure, access-controlled file.

", "narration_text": "You are Rapido Facil Exchange Co.'s sole point of contact for all law enforcement requests, subpoenas, and legal process. Staff who receive any law enforcement contact must route it to you immediately — without responding.\r\n\r\nWhen any law enforcement contact arrives:\r\nLog it immediately. Record: date received, requesting agency and officer, contact method, stated scope, response deadline, and disposition.\r\nKeep the log restricted. Tellers and customer-facing staff must not have access.\r\n\r\nWhen a subpoena arrives:\r\nVerify it is facially valid: proper court or agency caption, authorized signature, and a return date.\r\nNotify counsel if the return date is fewer than 10 business days away or if the scope is ambiguous.\r\nSearch all records systems for responsive materials — transaction files, CIP records, identification copies, and monitoring logs.\r\nCompile responsive documents. Do not include any SAR or SAR-related information.\r\nProduce documents by the return date. Retain copies of all produced materials. Log the completed response.\r\n\r\nWhen a National Security Letter (NSL) arrives:\r\nEscalate to counsel immediately — before any other action.\r\nDo not discuss receipt of the NSL with any employee beyond those required to respond.\r\nComply with all record production requirements within the specified timeframe.\r\nDocument the NSL in a secure, segregated log accessible only to you and counsel.\r\n\r\nSAR confidentiality — always:\r\nDo not confirm, deny, or disclose the existence of any SAR to anyone — customers, civil subpoenas, or informal requests.\r\nIf confirmation is sought through legal process, notify FinCEN and consult counsel before producing any records.\r\n\r\nWhen a verbal law enforcement request arrives:\r\nLog it immediately. Record the officer's name, agency, and badge number if provided.\r\nDo not produce any records or customer information. A written request or subpoena is required first.\r\n\r\nConfidentiality:\r\nDo not disclose to any customer or third party that a request, subpoena, or NSL has been received. Disclosure is permitted only upon written advice of counsel.\r\n\r\nRetention:\r\nRetain all law enforcement request documentation for a minimum of five years. This includes the original request, Rapido Facil Exchange Co.'s response, copies of all produced records, and all related correspondence. Store in a secure, access-controlled file." }