Envíos de Valores La Nacional Corp.
BANK SECRECY ACT AND ANTI-MONEY LAUNDERING
POLICY STATEMENT

Know Your Agent Policy

Another effective way to prevent criminals from using La Nacional is to adopt and follow an effective Know Your Agent policy. The vast majority of La Nacional transactions with customers are conducted by Agents located throughout the United States. Therefore, La Nacional’s Know Your Agent policy requires La Nacional to conduct due diligence to become familiar with each Agent and its principals and business prior to establishing the relationship. La Nacional’s Know Your Agent policy also requires it to monitor transactions to detect patterns of Agent activity that may indicate structuring to evade BSA reporting or recordkeeping requirements or any La Nacional procedures, possible money laundering or other criminal or unusual activity so that appropriate action may be taken, including reporting the activity to proper governmental authorities. La Nacional has put in place Bank Secrecy Act and Anti-Money Laundering Procedures (Compliance Handbook), which contain procedures Agents are required to follow when processing La Nacional transactions. Bank Secrecy Act and Anti-Money Laundering Compliance Program La Nacional’s Know Your Customer and Know Your Agent policies are essential parts of La Nacional’s strong company-wide Bank Secrecy Act and anti-money laundering compliance program (the “Program”), which consists of the following four components:

a) Designation of an officer responsible for day to day compliance with the Program;
b) A system of internal controls to monitor compliance;
c) Training of appropriate personnel; and
d) Independent testing of compliance with the Program

The Program has been adopted by La Nacional’s Board of Directors and is put into practice through the Compliance Handbook (Compliance Handbook is hereinafter referred to together as the “La Nacional Procedures”). La Nacional's Compliance Officer has been designated as the officer responsible for coordinating and monitoring day-to-day compliance with the Program.

          To this end, it is the policy of La Nacional to:

1. Comply with the reporting and recordkeeping requirements of the Bank Secrecy Act and its implementing regulations (collectively referred to as the "BSA"), including, filing CTRs and keeping records of wire transfers and cash sales of monetary instruments of $3,000 and over;

2. Maintain all records and copies of all reports required by the BSA for at least five years;

3. Maintain and update the Program as appropriate

4. La Nacional vigorously follow its Know Your Customer policy as implemented by the La Nacional Procedures by:

a. Requiring identifying and other customer information at the thresholds set by La Nacional prior to processing transactions;

b. Refusing to process a transaction if the conductor fails to provide required identification or provides information that appears to be false or inconsistent or if the transaction is indicative of structuring to evade BSA reporting or recordkeeping requirements or the La Nacional Procedures, possible money laundering or other criminal or unusual activity; and

c. Being alert to and monitoring transactions to identify currency transactions that are reportable on a CTR, as well as customer activity that may be indicative of structuring to evade BSA reporting or recordkeeping requirements or the La Nacional Procedures, possible money laundering or other criminal or unusual activity;

 5. La Nacional vigorously follow its "Know Your Agent" policy as implemented by the La Nacional Procedures by: a. Conducting due diligence on each Agent prior to entering into a relationship;
 b. Assisting each Agent in complying with the BSA by providing a summary of the BSA and anti-money laundering laws as well as the Agent Procedures;
c. Requiring each Agent to report activity that may be indicative of structuring to evade BSA reporting or recordkeeping requirements or the La Nacional Procedures, possible money laundering or other criminal or unusual activity involving a La Nacional customer to the proper government authorities, as well as provide a copy of each report to La Nacional;

d. Implementing controls to monitor transactions to detect patterns of Agent activity that may be indicative of structuring to evade BSA reporting or recordkeeping requirements or the La Nacional Procedures, possible money laundering or other criminal or unusual activity; and
e. Taking appropriate action with respect to any Agent that La Nacional has reported to the government for engaging in known or suspected criminal activity, which may include terminating the Agent’s Agency Agreement with La Nacional;
6. Promptly refer known or suspected structuring to evade BSA reporting or recordkeeping requirements or the La Nacional Procedures, possible money laundering or other criminal or unusual activity involving any customer or Agent to the Compliance Officer, who after investigation, will promptly report known or suspected criminal activity to the proper government authorities, consistent with applicable federal and state laws and regulations;
7. Never to give any advice or other assistance to customers or Agents regarding how to structure currency transactions or to evade the BSA reporting or recordkeeping requirements or the La Nacional Procedures; and
8. Cooperate fully with law enforcement authorities within the confines of applicable law.