The Securities Securities Compliance Program La Nacional Corp. (LA NACIONAL) was created to comply with all laws and regulations related to the financial services industry (MSB), such as: The Banking Secrecy Act (BSA), Office Control of Foreign Assets (OFAC), the US Patriot Act UU of 2001 and all related federal and state laws and regulations within the money services industry applied to money business services such as LA NACIONAL.

The Legal Compliance program of LA NACIONAL complies with Section 352 of the US Patriot Act. UU of 2001, which states that a compliance program must include, at a minimum, the following four pillars:

• Appropriate controls, policies and procedures
• Appointment of a Compliance Officer
• Independent review of the compliance program
• Continuous training program

Appropriate controls, policies and procedures.

The company has created a Legal Compliance Program that incorporates all policies and procedures related to BSA compliance and the USA Patriot Act. UU In the prevention of money laundering. The Compliance Program also details the compliance rules with the OFAC list, the “Know Your Customer” (KYC) procedures and the registration requirements, among other requirements.

Due to the importance in the implementation of a compliance program, LA NACIONAL has created a “Manual to Fight Money Laundering for Agents”. In this manual, the company specifies the responsibilities of the agents, not only under the law, but also under the policies and procedures established by LA NACIONAL in its compliance program.

Appointment of Compliance Officer

To ensure proper performance, the company has appointed a Chief Compliance Officer (CCO) who is a licensed attorney and a Certified Anti-Money Laundering specialist with more than 30 years of experience in the financial services industry and who he really understands the importance of the regulatory regime that covers money services companies.

The CCO functionally reports directly to the Board of Directors and administratively to the president (CEO) of LA NACIONAL. The Head of Compliance has an interdisciplinary team of well-trained staff that assists in the supervision and monitoring of the multiple functions of the compliance department.

Independent Reviews of the Compliance Program.

Every year, LA NACIONAL hires a recognized independent consulting firm that evaluates its AML / BSA program and examines its internal policies and processes, comparing them with high standards within the industry, as well as new regulatory developments within the financial system. I know. UU Based on this, they make recommendations and / or suggest adjustments to help maintain and improve the Compliance Program of LA NACIONAL, as a result of the foregoing, LA NACIONAL has implemented and automated multiple review and supervision processes that help improve the way in which that their systems monitor and detect unusual activities, monitor ongoing training policies as well as contribute to internal due diligence processes that take place through their systems, with the active participation of compliance personnel. These automated processes take into account all existing regulatory requirements for such work, as a result of the foregoing, each transaction is reviewed to verify compliance with AML / BSA, OFAC, the Bank Secrecy Act and any other regulations that may apply.

Continuous Training Program

LA NACIONAL has established a training program that addresses all related regulatory issues in each state in which it is licensed, including AML / BSA requirements, financial abuse to seniors and the regulation of the Consumer Financial Protection Bureau (CFPB), among many other topics. In this sense, LA NACIONAL fosters a high level of awareness among all its employees, including the members of the board of directors, its executives, its directors and its other members in the different departments, including the employees of its own branches and in particular, the members of its Compliance department.

The Chief Compliance Officer is directly responsible for implementing and improving the Compliance Program. LA NACIONAL maintains updated records of compliance training. A copy of the “Manual Against Money Laundering” created specifically for them is distributed among the agents, once the process of incorporation as an agent is completed. The compliance department also employs specialists whose functions are adequate training of new agents and monitoring the training of current agents. The Compliance Officer makes periodic visits to the agents to evaluate the training provided and usually sends updates through the computer system, used by the agents to carry out transactions, on the new regulatory developments applicable to the MSBs.

Money laundering is a vital component of drug trafficking and other crimes around the world. Money laundering is the process by which the nature or the source of illegal funds is hidden and it is masked to look legitimate

In the United States, the Bank Secrecy Act requires Money Services Businesses and other financial institutions to submit reports of foreign exchange transactions of more than $10,000 and to maintain a variety of registers, to assist the government in the prevention and detection of criminal activity, including the identification records of electronic transfers and cash sales of monetary instruments of     $3,000 or more. In addition, the Bank Secrecy Act makes it an offense to “structuring” or breaking the operations below the registration requirements and filing to evade the BSA reporting requirements or place. Structuring or not complying with the Law of Secret Bank may result in the imposition of great civil and criminal sanctions proceedings against the financial institution and any employee involved in the transaction. People can also be jailed for up to 10 years, and the money involved in the transaction may be impounded.

In the framework of the Anti-money laundering laws in the US, it is also a crime for any person to knowingly participate in any financial transaction, commercial or international transport or funds transfer which origin may be from drug trafficking or any other criminal activity. The knowledge can be created by verifying that the person was “voluntarily blind” or “deliberately indifferent” to the source or origin of the funds. Violations of the laws anti money laundering may be more serious and severe violations of the Bank Secrecy Act. The companies and persons convicted of money laundering can be fined up to $500,000 or double the value of the laundered funds, whichever is greater, for each violation and individuals can face up to 20 years in prison. In addition, the government can confiscate and forfeit the proceeds of drug trafficking and other crimes and any property from and/or involved in criminal activity. The mere fact allegedly associated with money launderers may result in the loss of the good reputation of financial institution and the trust of its customers.

MSB have become vulnerable to the potential money laundering schemes because, as banks, enable the movement of funds to almost any part of the world. Recent criminal investigations have shown that money launderers can transfer money in smaller amounts of $ 10,000 to evade reporting requirements of cash transactions, using false identification to transmit funds and buy money orders and traveler’s checks and sending wire transfers for amounts less than $3,000 to avoid identification requirements.

Compliance Policy

Shipping of Values La Nacional Corp. (“La Nacional”) is committed to complying fully with not only the letter of the Law of secrecy of the Bank but also its spirit, and to take active measures to detect, prevent and report to the appropriate government authorities, to the extent permitted by applicable laws and regulations, and suspected violations of the Bank Secrecy Act, money laundering of the Statute and other crimes. While the vast majority of the funds transferred by La Nacional operations are transactions from the United States to other countries (for example, the money is sent by people who work in the United States to their families outside of the United States or by companies which wish to transfer funds rapidly abroad), it is conceivable that some customers may try to use the products of La Nacional to move the money illegally originated, without the knowledge of La Nacional.

Know Your Customer Policy

An effective way to prevent criminals from using the services of La Nacional is to adopt and follow an effective “Know your Customer” policy. The “Know your Customer” policy of La Nacional requires that La Nacional itself and its agents make a reasonable effort to determine the true identity of each client and to be alert of the customers who are users of the products and services of La Nacional and make sure it is not victim of illegal practices. Therefore, La Nacional has implemented procedures to comply with the Bank Secrecy Act and the Anti-money laundering (Compliance Manual) to employees and agents, which, among other things, has strict procedures for getting the identification and other information of the client under the restrictions stated by La Nacional before it makes any transfer. The information obtained to send and receive transactions is also used for control purposes to identify transactions that are reported in the reports of cash transactions (“CTR”), as well as the possible structuring to evade the BSA reporting or registration requirements or any process of La Nacional, the possible money-laundering or other criminal activity or unusual activity is to be informed to the corresponding governmental authorities.

Another effective way to prevent criminals from using the services of La Nacional is adopting and following an effective policy of “Know your agent”. The great majority of transactions of La Nacional with customers are carried out by the agents located in the United States. Therefore, the policy “Know your agent” of La Nacional requires carrying out due diligence to familiarize itself with each of its agents, its directors and business before establishing the relationship. The policy of the “Know your agent” of La Nacional also requires it to monitor the transactions to detect patterns of activity of agents that can indicate the structuring to evade the BSA reporting or registration requirements or any national procedures, possible money laundering or any unusual or criminal activity so that they can act appropriately and report the activity, if necessary, to the corresponding government authorities. La Nacional has implemented procedures to comply with the Bank Secrecy Act and Anti-money laundering (Compliance Manual), which have the procedures of agents who are obliged to follow with the procedures of La Nacional transactions.

Legal Compliance Program: Bank Secrecy Act and Anti-money laundering.

The Policies Know your customer and Know Your La Nacional Agent are essential parts of its strong compliance program throughout the company in compliance with the Bank Secrecy Act and Anti-money laundering (the “Program”), which consists of the following four components:

(A) Designation of an officer-in-Charge of the day-to-day operation of the Program;
(B) a system of internal controls for monitoring;
(C) The training of appropriate personnel, and
D)Independent tests of the compliance program.

The program has been adopted by the Board of Directors of La Nacional and put into practice through the Compliance Manual (hereinafter referred to as “Procedures of La Nacional”). The Compliance Officer of La Nacional Compliance has been appointed as the official responsible for coordinating and monitoring the day-to-day compliance with the Program.

Therefore, the policy of La Nacional is:

  1. To comply with the requirements of information and archives of the Bank Secrecy Act and its implementing regulations (hereinafter referred to as the “BSA”), including the presentation of CTR and keep records of bank transfers and cash sales of monetary instruments $3,000 and more;
  2. Keep all records and copies of all reports required by the BSA for at least five years;
  3. Keep and update the program as the case may be.
  4. La Nacional strongly continues its own policy of Know your customer as it applies on its own procedures:
  5. which require the identification and other information of the client limited by La Nacional before the processing of transactions;
  6. Refusing to process a transaction if the one making the transaction does not have the required identification or provides information that appears to be false or incoherent, or if the transaction is indicative of the structuring to evade the BSA reporting or registration requirements or La Nacional procedures, possible money laundering or other criminals or unusual activity, and
  7. Be alert and control of transactions to identify currency transactions that are reported in the CTR, as well as customer activity that may be indicative of the structuring to evade the BSA reporting or registration requirements or La Nacional procedures, money-laundering possible or criminal or other unusual activity;
  8. La Nacional continues its policy of vigorously “Know your agent” implemented by its procedures:
  9. The realization of the due diligence on each agent, before entering into a relationship;
  10. Help each agent in compliance with the BSA, providing a summary of the BSA and money laundering against the laws, as well as the procedures of Agent;
  11. Requires that each agent report of activities that may be indicative of the structuring to evade the BSA reporting or registration requirements or La Nacional procedures, money-laundering as possible or unusual or other criminal activity involving a client of La Nacional to before the government authorities, as well as provide a copy of each report of La Nacional;
  12. The implementation of controls to oversee the operations to detect patterns of agent activity that may be indicative of the structuring to evade the BSA reporting or registration requirements or La Nacional procedures, money-laundering as possible or unusual or other criminal activity, and
  13. By taking appropriate measures regarding any agent of La Nacional which it had advised the Government to participate in with a well-known or suspected of criminal activity, which may include completion of an agent of La Nacional or of the Agreement with La Nacional;
  14. Immediately relates if known or suspected a case of structuring in evading the BSA reporting or registration requirements of La Nacional procedures, money-laundering possible or other unusual or criminal activity involving any customer or agent to the Compliance Officer, who, after an investigation, it shall inform without delay if it knows or suspects of criminal activity, to the corresponding government authorities, sticking to the applicable state and federal laws and regulations;
  15. Never give any advice or other assistance to customers or agents regarding the way of structuring currency transactions or to avoid the submission of reports or records BSA requirements or procedures of La Nacional, and
  16. Fully cooperate with law enforcement authorities within the limits of the applicable law.

It is the responsibility of each employee, officer and director of La Nacional to read, understand, and strictly adhere to this policy statement of La Nacional compliance with the BSA program and Anti-money laundering, policies and procedures. Questions should be directed to the Compliance Officer.

Violations of the BSA program and Anti-money-laundering in La Nacional, its policies and procedures may be grounds for disciplinary action, up to and including termination of employment.

This transaction is subject to the regulations and conditions stipulated the receipt herein. Its signature is its acceptance. The receipt herein is invalid if it is not processed through the computer system of La Nacional and if it does not have document printed by computer of the name and address of the agent and correct number of receipt. Envío de Valores La Nacional Corp. (La Nacional) is liable for any delay or non-delivery. Except as stated below.

Customers requesting a return must bring the original receipt and photo identification, to the place indicated on the front of the receipt. Return will not be applicable to be made if there shall be any error in the identification or information provided by the customer. Claims may require (15) business days to be resolved, additional charges may be included if an error was made by the client. We are not obliged to making any refunds for delayed payments until we receive confirmation of cancellation of shipment from our correspondent. Claims shall not be accepted after the 180 days of the date of this receipt.

We shall not be liable for actions, loss or damage due to the result of not being able to locate the beneficiary or errors on identifying the name of the beneficiary or a result of declared war or not, censorship, lock, insurrection, civil commotion or any decree of law, late charges, regulations, or public control compulsions or domestic or foreign government de jure or de facto or any other agency as a result of other causes, and that they are off of our control, or any office, branch, correspondent or agent, whether or not in relation to the transfer described above or in relation to transfers accepted by us for the sole purpose of making it available abroad or on the outside, as described by concept in the order herein. All such risks shall be borne by the customer. If for any reason the postage and packing has not been paid and the money not claimed or provides additional instructions, during the period of six months from the date which it was sent, there shall be at a cost of $2.00 per month. This charge will be obtained from the transaction sent to compensate the additional La Nacional administrative maintenance associated with such transactions.

La Nacional is a company dedicated to sending money. It is authorized and subject to the regulations of the Department of Banks of New York and other States. Any claim in New York can be directed to “The New York State Banking Department”, located in the 1 State St. New York, NY 10004-1417. Attn: Consumer Service Division. Claims of other states may be sent to the national, 7901 Southpark Plaza Suite 216, Littleton, CO 80120.

Please see a table below with the information of different states where La Nacional has operations.

Pursuant to the requirements of Title V of the Gramm-Leach-Bliley Act Envios de Valores la Nacional Corp, (“La Nacional”) does not disclose any  on-public personal information obtained during the course of processing the money remittance orders, about our customers or former customers  to anyone, except as permitted or required by law and as required to process the money transmission order in accordance with the customer’s  instructions.

La Nacional, as a money transmitter, is considered an MSB and like all providers of financial services is required by law to inform its consumers of the policies and procedures regarding the privacy of its consumers’ information.

1. Collection Sources:
La Nacional collects non-public personal information about its consumers that is provided by the consumers as part of the services we provide the consumers.
• Information La Nacional receive from its consumers while processing their money remittance orders.
• Information about the transactions with La Nacional.
• Information La Nacional receives from its agents.

2. Privacy and Disclosure Policy:
La Nacional does not disclose any non-public personal information obtained during the course of processing the money remittance orders, about its consumers or former consumers to anyone, except as required to process the transaction requested by the consumer and as permitted or required by law.

As an example, permitted disclosures include:
• Employees as involved in the processing of the money remittance orders.
• Data processing company, as part of the data entry and processing of the money transfer order.
• Correspondent paying agents, as part of the money remittance order payment and processing.

3. Confidentiality:
La Nacional maintains physical, electronic, and procedural safeguards that comply with Federal and State laws and regulations to protect its consumers’ non-public personal information. For example, La Nacional’s transactional data is encrypted and backed-up on a real time basis in a mirror server in a safe remote co-location, access to transactional information is restricted by password, and privileges in accordance with the operator’s functions and responsibilities, all documents related to transactions are maintained in a safe storage area with access limited to authorized personnel.

California Privacy Policy

The California Consumer Privacy Act of 2020 (CCPA) applies to La Nacional’s business activities with California consumers. To comply with the requirements of the CCPA, La Nacional has developed the following policies and procedures:

Policy: La Nacional is not required to comply with a consumer’s request to delete the consumer’s personal information as it is necessary to complete the transaction requested by the consumer. La Nacional will protect its California consumers’ personal information it collects and will not sell or share the consumers’ personal information to third parties. La Nacional will only share the consumers’ personal information, (i) with third parties as required to complete the transaction requested by the consumer as outlined by the CCPA Section 1798.105(4)(1); (ii) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity as outlined by the CCPA Section 1798.105(4)(2); (iii) for internal uses that are aligned with the consumer’s expectations as outlined by the CCPA Section 1798.105 (4)(7); and (iv) to comply with a legal obligation as outlined by the CCPA Section 1798.105 (d)(8).

Procedures:

La Nacional will implement the following procedures to comply with the CCPA:
1. La Nacional in compliance with the CCPA Section 1798.100 (2) shall post disclosures at its
California owned locations and authorized agents informing its consumers that in order to
process the transaction and based on transaction amounts will collect the following personal
information:
a. Full name of consumer
b. Full address of consumer
c. Telephone number of consumers
d. Full, name of recipient
e. Recipient’s address
f. Recipient’s telephone number, if available.
g. Based on transaction amount the following additional information:
i. Copy of valid identification
ii. Date of birth
iii. Social security number or TIN
iv. Name and address of employer
v. Occupation
vi. Source of funds

2. La Nacional will implement a disclosure in its informational website disclosing information on the two methods that the consumer can request personal information collected in connection with a transaction or to not sell or destroy: (i) a disclosure of and email address on its website asking the customer to send an email requesting the information; and (ii) a toll-free telephone number.

3. LA Nacional must respond free of charge to a consumer within 45 days from the date of the receipt of the request unless the time to respond has been extended by an additional 45 days.

4. When the response if provided to the consumer it must include consumer’s personal information collected including the type of information shared with third parties and purpose for collecting the information.

5. La Nacional’s website must disclose La Nacional’s privacy policy including California’s privacy policy in compliance with the CCPA. The privacy policy is: La Nacional does not disclose any nonpublic information about our customers or former customers, except as permitted by law or as required to process the customer’s transaction in addition our California privacy policy in compliance with the CCPA is: La Nacional does not sell its customers’ personal information. La Nacional does not destroy its customers information as permitted by the CCPA Section 1798.105(d). La Nacional shares its customers’ personal information with third parties in order to complete the transaction requested by its California consumers.

California Division 1.4 Disclosure of Nonpublic Personal Information of Consumers.

The California Financial Information Privacy Act (Division 1.4, commencing with section 4050, of the Financial Code) (“Division 1.4”) became effective on July 1, 2004, and as stated in the 2021 California Financial Code Division 1.4 – California Financial Information Privacy Act. Division
1.4 broadly regulates the sharing of nonpublic personal information of consumers. Division 1.2 prohibits a financial institution from disclosing any non-public personal information of a consumer to a non-affiliated third party without first having obtained the consent of the consumer to that information sharing. The law provides exceptions to the requirement of obtaining the consumers’ consent. Section 4056 states in pertinent part that La Nacional is allowed to disclosed its consumers’ nonpublic personal financial information when “the nonpublic personal information is
necessary to effect, administer, or enforce a transaction requested or authorized by the consumer” as in the payment of the wire transfer requested by the consumer.

La Nacional’s policy to comply with California’s Division 1.4 is not to disclose the customers’
nonpublic information to nonaffiliated third parties without first obtaining the customers’ consent
unless the disclosure is permitted by the California Financial Information Privacy Act without the
customers’ consent.

La Nacional’s Privacy Policy and California’s CCPA and Division 1.4 requirements were last
reviewed and approved by the Board of Directors on June 24, 2021.