Envíos de Valores La Nacional Corp.
Overview of Compliance Program
Last Updated: April 26, 2010

The compliance program of Envíos de Valores La Nacional Corp was created with the purpose of complying with all required laws and regulations for Money Service Businesses, such as: the BSA, OFAC rules, the USA Patriot Act and all other Federal and State regulations.

The company’s compliance program is accordance to section 352 of the USA Patriot Act which states that a compliance program should include the following four items:

• Written Policies, Procedures and Controls
• Designated Compliance Officer
• Independent testing of the compliance program
• Proper training program

Written Policies, Procedures and Controls

To assure proper compliance, the company has designated a Chief Compliance Officer, CAMS certified, who reports directly to the President of the company. The Chief Compliance Officer has an Assistant Compliance Officer and an additional staff of 4 people responsible for the day to day functions of the compliance department.

Independent Testing of compliance program

The company has engaged the services of Michael McDonald and Associates for the independent testing of the compliance program. The scope of the independent testing of the compliance program includes stress testing of the agents.

Proper Training of Staff

The company has established a compliance training program addresses to all agents, corporate employees (including cashiers) and the compliance department staff. The Chief Compliance Officer is responsible for the implementation of the company’s compliance program. Training logs are kept for all compliance training provided by the company. Agents are provided with a copy of the company’s “Anti-Money Laundering Manual for Agents” upon their acceptance into the company. The compliance department also employs training specialists whose responsibilities rely on the proper training of new agents and the follow up training on current agents. The Chief Compliance Officer periodically visits locations to establish that proper training was provided to the agents and periodically sends correspondence to the company’s point of sales regarding important compliance issues applicable to MSBs.

Functions of the Compliance Program

The company has established and automated process to monitor all transactions. This automated process takes into account all regulatory requirements under the law. Every transaction is checked for OFAC compliance as well as Bank Secrecy Act compliance.