{
  "body_html": "<h2>Disaster Recovery and Business Continuity</h2>\n<p>When BSA-critical systems are unavailable, follow these procedures.</p>\n<p><strong>CTR filing.</strong> Complete FinCEN Form 112 by hand using pre-stored paper forms at your location. Mail the completed form to the address printed on the form. The 15-day deadline does not extend during an outage. A missed deadline is a regulatory violation. Log outage dates, each form mailed, and the mailing date. Re-file electronically if FinCEN instructs you to after service is restored.</p>\n<p><strong>SAR filing.</strong> Complete FinCEN Form 111 by hand using pre-stored paper forms at your location. Mail the completed form to the address printed on the form. The 30-calendar-day deadline does not extend during an outage. A missed deadline is a regulatory violation. Log outage dates, each form mailed, and the mailing date. Re-file electronically if FinCEN instructs you to after service is restored.</p>\n<p><strong>OFAC screening.</strong> Screen every customer and transaction counterparty manually against the SDN List. Use OFAC's online search tool if internet is available. If internet is unavailable, use the downloaded SDN List PDF stored at your location — refresh it monthly. Do not process any transaction without OFAC screening. An unscreened transaction exposes Rapido Facil Exchange Co. to federal sanctions liability.</p>\n<p><strong>Transaction monitoring.</strong> A supervisor must manually review transaction logs when the core transaction system is unavailable.</p>\n<p><strong>Customer records.</strong> Access the encrypted cloud backup from any internet-connected device with authorized credentials. Encrypted USB backup drives at each location contain records for the prior 24 months.</p>\n<p><strong>Check cashing database.</strong> Continue cashing checks during a database outage. Submit all backlogged entries within 2 business days of system restoration. Missing this window violates Rapido Facil Exchange Co.'s Florida state-mandated reporting obligation.</p>\n<p><strong>Your availability.</strong> You must maintain a designated emergency contact number at all times. Record your phone number, secure email, and alternate contact channel in the Business Continuity Plan binder at each location. Review and update this information annually.</p>\n<p><strong>No backup BSA/AML Compliance Officer.</strong> If you are unavailable for an extended period, Rapido Facil Exchange Co. must immediately suspend check cashing operations. Do not allow untrained personnel to fulfill BSA compliance duties. Operations resume only when you return or a qualified backup is designated and trained. Continuing operations without qualified BSA oversight creates direct regulatory liability.</p>\n<p><strong>Vendor contingency records.</strong> For each BSA-critical vendor, document: the compliance function supported, the manual alternative active during failure, and the outage duration threshold that requires escalation. Update this documentation whenever a vendor contract is renewed, modified, or terminated.</p>\n<p><strong>Annual testing.</strong> Test all business continuity procedures annually. Each test must simulate at least one BSA-critical system failure. Verify that each manual alternative works as documented. Confirm your reachability during the test. Produce and sign a written test record. Retain all test records for five years. Document all gaps found during testing and remediate each gap before the next review cycle.</p>",
  "narration_text": "When BSA-critical systems are unavailable, follow these procedures.\r\n\r\nCTR filing. Complete FinCEN Form 112 by hand using pre-stored paper forms at your location. Mail the completed form to the address printed on the form. The 15-day deadline does not extend during an outage. A missed deadline is a regulatory violation. Log outage dates, each form mailed, and the mailing date. Re-file electronically if FinCEN instructs you to after service is restored.\r\n\r\nSAR filing. Complete FinCEN Form 111 by hand using pre-stored paper forms at your location. Mail the completed form to the address printed on the form. The 30-calendar-day deadline does not extend during an outage. A missed deadline is a regulatory violation. Log outage dates, each form mailed, and the mailing date. Re-file electronically if FinCEN instructs you to after service is restored.\r\n\r\nOFAC screening. Screen every customer and transaction counterparty manually against the SDN List. Use OFAC's online search tool if internet is available. If internet is unavailable, use the downloaded SDN List PDF stored at your location — refresh it monthly. Do not process any transaction without OFAC screening. An unscreened transaction exposes Rapido Facil Exchange Co. to federal sanctions liability.\r\n\r\nTransaction monitoring. A supervisor must manually review transaction logs when the core transaction system is unavailable.\r\n\r\nCustomer records. Access the encrypted cloud backup from any internet-connected device with authorized credentials. Encrypted USB backup drives at each location contain records for the prior 24 months.\r\n\r\nCheck cashing database. Continue cashing checks during a database outage. Submit all backlogged entries within 2 business days of system restoration. Missing this window violates Rapido Facil Exchange Co.'s Florida state-mandated reporting obligation.\r\n\r\nYour availability. You must maintain a designated emergency contact number at all times. Record your phone number, secure email, and alternate contact channel in the Business Continuity Plan binder at each location. Review and update this information annually.\r\n\r\nNo backup BSA/AML Compliance Officer. If you are unavailable for an extended period, Rapido Facil Exchange Co. must immediately suspend check cashing operations. Do not allow untrained personnel to fulfill BSA compliance duties. Operations resume only when you return or a qualified backup is designated and trained. Continuing operations without qualified BSA oversight creates direct regulatory liability.\r\n\r\nVendor contingency records. For each BSA-critical vendor, document: the compliance function supported, the manual alternative active during failure, and the outage duration threshold that requires escalation. Update this documentation whenever a vendor contract is renewed, modified, or terminated.\r\n\r\nAnnual testing. Test all business continuity procedures annually. Each test must simulate at least one BSA-critical system failure. Verify that each manual alternative works as documented. Confirm your reachability during the test. Produce and sign a written test record. Retain all test records for five years. Document all gaps found during testing and remediate each gap before the next review cycle."
}