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

POLICY STATEMENT

Money laundering is a vital component of drug trafficking and other crimes throughout the world. Money laundering is the process by which the existence, nature or source of illegal funds is concealed and then disguised to appear legitimate. In the United States, the Bank Secrecy Act requires Money Services Business and other financial institutions to file reports for currency transactions of over $10,000 and to maintain a variety of records to assist the government in the prevention and detection of criminal activity, including identification records for wire transfers and cash sales of monetary instruments of $3,000 and over. In addition, the Bank Secrecy Act makes it a crime to “structure” or break down transactions below the reporting or recordkeeping thresholds to evade BSA reporting or recordkeeping requirements. Structuring or failing to comply with the Bank Secrecy Act can result in the imposition of large criminal and civil penalties against the financial institution and any employee involved in the transaction. Individuals also may be imprisoned for up to 10 years, and the monies involved in the transaction may be forfeited.

Under the U.S. money laundering statutes, it also is a crime for any person to knowingly engage in any commercial or financial transaction or international transportation or transmission of funds with the proceeds of drug trafficking or other criminal activity. Knowledge may be established by proving that the person was "willfully blind" or "deliberately indifferent" to the source or origin of the funds. Violations of the money laundering statutes can result in even more severe problems than violations of the Bank Secrecy Act. Businesses and individuals convicted of money laundering can be fined up to $500,000 or twice the value of the funds laundered, whichever is greater, for each violation and individuals can face up to 20 years in prison. In addition, the government can seize and forfeit the proceeds of drug trafficking and other crimes and any property traceable to or involved in the criminal activity. Merely being alleged to be associated with money launderers can result in the loss of a financial institution's good reputation and the trust of its valued customers. MSB have become vulnerable to possible money laundering schemes because, like banks, they permit the movement of funds to almost anywhere in the world. Recent criminal investigations have shown that money launderers may be transmitting funds in amounts less than $10,000 to evade currency transaction reporting requirements, using false identification to transmit funds and purchasing money orders and traveler's checks and sending wire transfers in amounts less than $3,000 to avoid identification requirements.  

Compliance Policy

Envios De Valores La Nacional Corp. ("La Nacional") is committed to complying fully with not only the letter of the Bank Secrecy Act, but also its spirit, and to taking affirmative steps to detect, prevent and report to appropriate government authorities, to the extent permitted by applicable laws and regulations, known and suspected violations of the Bank Secrecy Act, money laundering statutes and other crimes. While the vast majority of La Nacional’s money transfers are legitimate transactions from the United States to other countries (e.g., money is sent by individuals working in the United States to their families outside of the United States or by businesses desiring to move funds expeditiously abroad), it is conceivable that customers could try to use La Nacional’s products and services to move illegally-derived money without La Nacional’s knowledge.

Know Your Customer Policy

One effective way to prevent criminals from using La Nacional is to adopt and follow an effective ”Know Your Customer" policy. La Nacional’s Know your Customer policy requires La Nacional and its agents (“Agents”) to make a reasonable effort to determine the true identity of each customer and to be alert to each customer’s use of La Nacional’s products and services to ensure that La Nacional does not unwittingly assist in illegal practices. It is for this reason that La Nacional has put in place Bank Secrecy Act and Anti-Money Laundering Procedures (Compliance Handbook) for Employees and agents, which, among other things, contain strict procedures for obtaining identifying and other customer information at the thresholds set by La Nacional prior to processing transactions. The information obtained for send and receive transactions also is used for monitoring purposes to identify transactions that are reportable on Currency Transaction Reports (“CTR”), as well as possible structuring to evade BSA reporting or recordkeeping requirements or any La Nacional procedures, possible money laundering or other criminal or unusual activity for reporting to proper governmental authorities.