Know your Customer Policy - KNOW YOUR CUSTOMER _KYC_ POLICY

					                    KNOW YOUR CUSTOMER (KYC) POLICY

Under the guidelines of the Treasury Department's directive Merchant Service Businesses,
which Su Casa de Cambio is defined as one, must comply with all aspects of the Bank Secrecy
Act. With this in mind, prudent business practices confirm that financial institutions (Su Casa de
Cambio meets this definition of financial institution also as it offers check cashing services and
sells money orders to consumers) need to know the normal and routine activities of their
customers to better serve their needs. Additionally, in the U.S. banking environment, the Bank
Secrecy Act (BSA) requires financial institutions to take reasonable steps to ensure knowledge
of its customers' normal and routine business activities. Many of our customers may not have a
routine activity. To address these requirements, Su Casa de Cambio is establishing this Know
Your Customer (KYC) policy to define what efforts the company will take to meet the BSA
requirement and to fully serve our customers.

Our customer's privacy is important to the company; therefore, the Su Casa de Cambio "Company"
will obtain and use only that information necessary to comply with the regulation. Employees will be
instructed on this policy and our general privacy policy regarding customer information.

Due diligence procedures have been established by Su Casa de Cambio to comply with the Know
Your Customer Policy to include a system for:
•   Determination of the identity of the company's new & repeat customers

•   Determination of the customer's sources of funds for transactions involving the company

•   Understanding our customers' normal and expected transactions

•   Determining if a transaction is suspicious, in accordance with FinCen's suspicious activity
    reporting regulations and reporting accordingly

Whenever a customer's actions seem in a suspicious manner, which may or may not be identified in
this KYC policy, the employee observing the behavior or action must report it to a supervisor, who
will refer the incident appropriately to the Head Office Administration Department. Administration
must either monitor the account, directly or indirectly, or notify the appropriate law enforcement
agencies. Suspicious activities should be reported regardless of the customer, the size of the
transaction, or the nature of the activity. After an appropriate investigation of the facts, Su Casa de
Cambio may file a Suspicious Activity Report (SAR). Refer to the instructions for completion of a
SAR form in Su Casa de Cambio compliance & procedures manual.

To ensure compliance to KYC, Su Casa de Cambio has established a procedure for internal controls
in all of its store's locations. Additionally, transactions are monitored on a transaction basis through
the review of various reports such as the Money Order Log for transactions over $2,000 and
routine reports prepared by management. Digital's auditor and compliance officer conducts
independent testing for compliance with all regulatory agency guidelines that the company falls
One of the most important, if not the most important means by which the company can hope to
avoid criminal exposure from customers who use the resources of the company for illicit purposes is
to have a clear and concise understanding of each customer's practices. The adoption of "Know
Your Customer" guidelines or procedures by financial institutions has proven extremely effective in
detecting suspicious activity by customers in a timely manner.

Even though not required by regulation or statute, it is imperative that financial institutions adopt
"Know Your Customer" guidelines or procedures to enable the immediate detection and identification
of suspicious activity.

The concept of "Know Your Customer" is, by design, not explicitly defined so that each institution
can adopt procedures best suited for its own operations. An effective policy establishes specific
line responsibilities and policies appropriate to the size, location, and type of business.


1. A "Know Your Customer" policy increases the likelihood the company is in compliance with all
statutes and regulations and adheres to sound and recognized business practices.

2. A "Know Your Customer" policy decreases the likelihood the company will become a
victim of illegal activities perpetrated by a customer.

3. A "Know Your Customer" policy that is effective will protect the good name and reputation of the

4. A "Know Your Customer" policy will not interfere with the relationship of the company
with its good customers.

At the present time there are no statutory mandates requiring a "Know Your Customer Policy" or
specifying the contents of such a policy. However, in order to develop and maintain a practical
and useful policy, Su Casa de Cambio has incorporated the following principles into their business

1. The company will make a reasonable effort to determine the true identity of all customers requesting

2. Identification will be obtained from all customers (whether new or established) prior to
providing check-cashing services or granting of payday loan advances.

4. Evidence of identity will be obtained from customers seeking to conduct significant business
transactions; and

5. Our employees have been trained to be aware of any unusual transaction activity or
activity that is disproportionate to the customer's known business.
An integral part of our effective "Know Your Customer" policy is our comprehensive
knowledge of the transactions carried out by our customers. Therefore, it is necessary that the
"Know Your Customer" procedures established by the company allow for the collection of
sufficient information to develop a "transaction profile" of each customer. The primary objective
of such procedures is to enable the company to predict with relative certainty the types of
transactions in which a customer is likely to be engaged. Internal procedures have been
developed for monitoring transactions to determine if transactions occur which are
inconsistent with the customer's "transaction profile". Our "Know Your Customer" policy consists
of procedures that require proper identification of every customer at the time a relationship is
established. In addition, the company's employee training program provides examples of customer
behavior or activity, which may warrant investigation.

Identifying The Customer

As a general rule, a business relationship with the company should never be established until the
identity of a potential customer is satisfactorily established. If a potential customer refuses to
produce any of the requested information, the relationship should not be established. Likewise, if
requested follow-up information is not forthcoming, any relationship already begun should be

Treasury's Office Of Foreign Assets Control (OFAC)

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) administers laws
that impose economic sanctions against hostile foreign countries to further U.S. foreign policy
and national security objectives. Su Casa de Cambio understands the regulations regarding OFAC
and since it does offer

Wire Transfer services through UniGram a division of Merchants Bank of California, N.A. has
verified that UniGram and the Bank have strong compliance policies and procedures in place for
the monitoring of OF AC within its system. Also that an auditor and compliance officer for
UniGram and the Bank monitors the compliance procedures in place for OF AC and BSA

OF AC also is responsible for issuing regulations that restrict transactions by U.S. persons or
entities (including banks), located in the U.S. or abroad, with certain foreign countries, their
nationals or "specially designated nationals". OFAC regularly provides to banks, or banks may
subscribe to certain databases or other informational providers, including the Federal Register,
to receive current listings of foreign countries and designated nationals that are prohibited from
conducting business with any U.S. entity or individual. Violations of these laws can expose financial
institutions or companies to substantial penalties.

OFAC rules require financial institutions to identify transactions with prohibited entities. The rules
may require that they reject or freeze the funds involved in the transactions. In either event,
financial institutions or companies are required to notify OFAC when transactions with prohibited
entities are attempted or completed.

At a minimum, each institution/company should maintain a current listing of prohibited countries,
entities and individuals. New accounts should be compared to the OFAC list before opening
or wiring of funds, and established accounts should be regularly compared to current OFAC
listings. Failure to maintain policies and procedures to comply with OFAC rules is not a violation
of law; however, failure to block transactions with prohibited countries, entities or individuals may
expose the institution/company to substantial penalties.

OFAC "HotLine"
"A toll-free assistance line designated specifically for compliance inquiries. (1-800) 540-OFAC
(6322). OFAC makes representatives available to answer any questions regarding compliance
including assistance on identifying whether a particular account or transfer should be blocked.

Suspicious Activity Reports

Suspicious activities required to be reported are any transactions aggregating $5,000 or more
that involve potential money laundering or violations of the BSA. Suspicious transactions may
no longer be reported by using a CTR. If the suspicious transaction involves more than $10,000
in cash, a CTR and a SAR must be prepared and filed. If the suspicious transaction involves
between $5,000 and $10,000 in cash, only the SAR should be prepared and filed.

The SAR should be filed if the company knows, suspects, or has reason to suspect that:

1. The transaction involves funds derived from illegal activities or is intended or conducted in
order to hide or disguise funds or assets derived from illegal activities (including, without
limitation, the ownership, nature, source, location, or control of such funds or assets) as part of
a plan to violate or evade any federal law or regulation or to avoid any transaction reporting
requirement under federal law;

2. The transaction is designed to evade any regulations promulgated under the Bank Secrecy Act; or;

3. The transaction has no business or apparent lawful purpose or is not the sort of transaction in
which the particular customer would normally be expected to engage, and the company
knows of no reasonable explanation for the transaction after examining the available facts,
including the background and possible purpose of the transaction.

The SAR must be filed no later than 30 calendar days after the date of initial detection of
facts that may constitute a basis for filing a SAR. If no suspect was identified on the date of
detection of the incident requiring the filing, a company may delay filing a suspicious activity report
for an additional 30 calendar days to identify a suspect. In no case shall reporting be delayed
more than 60 days after the date of initial detection of a reportable transaction. The company's
designated officer or President should be promptly notified of any SAR
filed, and a copy of each SAR filed, along with supporting documentation, should be retained for
a period of five years from the date filed.

Confidentiality Of Reports

Suspicious activity reports are confidential. Any company subpoenaed or otherwise requested to
disclose a suspicious activity report or the information contained in a suspicious activity report shall
decline to produce the suspicious activity report or to provide any information that would disclose
that a suspicious activity report has been prepared or filed.

Examination Support / Suspicious Activity Report Database

FinCEN maintains a database containing information from SARs filed by all federally
insured financial institutions. Currently, the database is accessible only to specifically designated
personnel in the Washington Office and each Regional Office. If an examiner has reason to
believe suspicious the company under examination has not reported activity, the examiner may
request through the Regional Office contact a listing of SARs filed or copies of SARs filed. If
suspicious activity is discovered at the company under examination, the examiner also may utilize
the resources of the FinCEN database to obtain information concerning possible suspicious
activity involving the same person or entity at other federally insured financial institutions.

Currency And Banking Retrieval System

The Currency and Banking Retrieval System (CBRS) is a database of CTRs filed with the IRS. It is
maintained at the Internal Revenue Service Detroit Data Center. The Regional Office contact that
has access to the FinCEN database may also access the CBRS. The CBRS may be used to
verify CTRs filed by the company under examination if the examiner suspect's reports have not
been filed, or it may be used to provide information for further investigation of suspicious currency
transaction activity. Information required to obtain information from the CBRS includes:

(1) The name and taxpayer identification number of the filing company, if requesting information on
CTRs filed by a particular company,

(2) The taxpayer identification number of the party named in Part I and/or Part II of the CTR,
if seeking information on the subject(s) of the CTR; and

(3) The range of dates for which reports are requested. Examiners should take into consideration the
volume of CTRs filed by the company under examination when determining the range of dates

FinCEN Reports

FinCEN prepares a number of reports, which may aid examiners in targeting certain financial
institutions for special review of BSA compliance and in identifying money-laundering schemes.
Also available is the FinCEN Advisory that advises financial institutions, regulatory agencies, and
law enforcement agencies of trends and developments related to money laundering and financial