The BSA/AML Compliance Officer is 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 the BSA/AML Compliance Officer immediately. They must not provide any substantive response to the officer. This protects Rapido Facil Exchange Co. from unauthorized disclosures before legal review.
\nEvery law enforcement contact must be logged at the time of receipt. Each entry must include: date received, requesting agency and officer, contact method, stated scope of request, specified response deadline, and disposition. The log is maintained by the BSA/AML Compliance Officer and is not accessible to tellers or customer-facing staff. Restricting access prevents inadvertent disclosure of sensitive investigative activity.
\nWhen a subpoena arrives, verify it is facially valid. Confirm it contains a proper court or agency caption, an authorized signature, and a return date. Notify counsel if the return date is fewer than 10 business days away. Notify counsel also if the scope is ambiguous. Early counsel involvement prevents procedural errors that expose Rapido Facil Exchange Co. to liability. Search all records systems for responsive materials: transaction files, CIP records, identification copies, and monitoring logs. Compile responsive documents. Do not include any Suspicious Activity Report or SAR-related information in the production. Disclosure of a SAR is prohibited by federal law. Produce responsive documents by the return date. Retain copies of all produced materials. Copies create a record of what was disclosed. Log the completed response, recording the date produced and a description of materials provided.
\nUpon receipt of a National Security Letter, escalate to counsel immediately before taking any other action. NSLs carry statutory non-disclosure obligations that counsel must manage before any other steps proceed. Do not discuss receipt of the NSL with any employee beyond those required to respond. Unauthorized discussion violates the NSL's non-disclosure requirement. Comply with all record production requirements within the specified timeframe. Document the NSL in a secure, segregated log accessible only to the BSA/AML Compliance Officer and counsel. Segregation prevents accidental exposure of NSL receipt to unauthorized staff.
\nRapido Facil Exchange Co. does not confirm, deny, or disclose the existence of any Suspicious Activity Report. This prohibition applies to customer inquiries, civil subpoenas, and informal law enforcement requests. When a request appears designed to elicit whether a SAR was filed, decline to confirm or deny. If confirmation is sought through legal process, notify FinCEN. FinCEN manages SAR confidentiality at the federal level and must be informed when that confidentiality is legally tested. Consult counsel before producing any records that could reveal SAR filing status. Law enforcement presenting a grand jury subpoena or NSL may independently obtain underlying transaction records. Rapido Facil Exchange Co. may produce those underlying records without disclosing whether a SAR was filed. The underlying transaction records are legally separate from the SAR itself.
\nVerbal requests made in person by law enforcement at the counter must be logged immediately. Record the officer's name, agency, badge number if provided, and the nature of the request. Do not produce any records or customer information in response to a verbal request. A written request or subpoena is required before any records are produced. Written process creates a legal record of the demand and protects Rapido Facil Exchange Co. against claims of unauthorized disclosure.
\nDo not disclose to any customer or third party that a law enforcement request, subpoena, or NSL has been received. Disclosure is permitted only upon written advice of counsel that it is legally required. Premature disclosure can compromise an active investigation.
\nAll law enforcement request documentation must be retained for a minimum of five years. Retained materials include: the original request, Rapido Facil Exchange Co.'s response, copies of all produced records, and all related correspondence. Store these materials in a secure, access-controlled file maintained by the BSA/AML Compliance Officer. Five-year retention satisfies federal recordkeeping requirements applicable to licensed money services businesses.
", "narration_text": "The BSA/AML Compliance Officer is 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 the BSA/AML Compliance Officer immediately. They must not provide any substantive response to the officer. This protects Rapido Facil Exchange Co. from unauthorized disclosures before legal review.\r\n\r\nEvery law enforcement contact must be logged at the time of receipt. Each entry must include: date received, requesting agency and officer, contact method, stated scope of request, specified response deadline, and disposition. The log is maintained by the BSA/AML Compliance Officer and is not accessible to tellers or customer-facing staff. Restricting access prevents inadvertent disclosure of sensitive investigative activity.\r\n\r\nWhen a subpoena arrives, verify it is facially valid. Confirm it contains a proper court or agency caption, an authorized signature, and a return date. Notify counsel if the return date is fewer than 10 business days away. Notify counsel also if the scope is ambiguous. Early counsel involvement prevents procedural errors that expose Rapido Facil Exchange Co. to liability. Search all records systems for responsive materials: transaction files, CIP records, identification copies, and monitoring logs. Compile responsive documents. Do not include any Suspicious Activity Report or SAR-related information in the production. Disclosure of a SAR is prohibited by federal law. Produce responsive documents by the return date. Retain copies of all produced materials. Copies create a record of what was disclosed. Log the completed response, recording the date produced and a description of materials provided.\r\n\r\nUpon receipt of a National Security Letter, escalate to counsel immediately before taking any other action. NSLs carry statutory non-disclosure obligations that counsel must manage before any other steps proceed. Do not discuss receipt of the NSL with any employee beyond those required to respond. Unauthorized discussion violates the NSL's non-disclosure requirement. Comply with all record production requirements within the specified timeframe. Document the NSL in a secure, segregated log accessible only to the BSA/AML Compliance Officer and counsel. Segregation prevents accidental exposure of NSL receipt to unauthorized staff.\r\n\r\nRapido Facil Exchange Co. does not confirm, deny, or disclose the existence of any Suspicious Activity Report. This prohibition applies to customer inquiries, civil subpoenas, and informal law enforcement requests. When a request appears designed to elicit whether a SAR was filed, decline to confirm or deny. If confirmation is sought through legal process, notify FinCEN. FinCEN manages SAR confidentiality at the federal level and must be informed when that confidentiality is legally tested. Consult counsel before producing any records that could reveal SAR filing status. Law enforcement presenting a grand jury subpoena or NSL may independently obtain underlying transaction records. Rapido Facil Exchange Co. may produce those underlying records without disclosing whether a SAR was filed. The underlying transaction records are legally separate from the SAR itself.\r\n\r\nVerbal requests made in person by law enforcement at the counter must be logged immediately. Record the officer's name, agency, badge number if provided, and the nature of the request. Do not produce any records or customer information in response to a verbal request. A written request or subpoena is required before any records are produced. Written process creates a legal record of the demand and protects Rapido Facil Exchange Co. against claims of unauthorized disclosure.\r\n\r\nDo not disclose to any customer or third party that a law enforcement request, subpoena, or NSL has been received. Disclosure is permitted only upon written advice of counsel that it is legally required. Premature disclosure can compromise an active investigation.\r\n\r\nAll law enforcement request documentation must be retained for a minimum of five years. Retained materials include: the original request, Rapido Facil Exchange Co.'s response, copies of all produced records, and all related correspondence. Store these materials in a secure, access-controlled file maintained by the BSA/AML Compliance Officer. Five-year retention satisfies federal recordkeeping requirements applicable to licensed money services businesses." }