Compliance Guidelines February 17 th 2014

1. VENTURE Credit Union Compliance GuidelinesFebruary 17th 2014

2. Our Objective • The best of both worlds Complying with the FIU and FATCA Excellent Member Service Sustainable & Profitable VCU

3. Compliance –Step 1 (a)- Know your Member Step 1 (a) – Know Your Member Member Application Form Verification of Income Additional Information Form Verification of address Source of Funds Verification of IDs

4. Compliance Step 1 (b)- Know your Company • Step 1 (b) Know Your Company • Sole Traders/Partnerships • - Cert of Registration • - Copy of IDs • - Proof of Address for Owner or Company • Recent Financials • Source of Funds • Limited Liab. • Directors IDs • Certificate of Incorporation • Recent Annual Return Bye Laws • Resolution letter • Recent Financials • Source of Funds

5. Compliance Step 2- Ask yourself • Step 2 ASK yourself: Is there anything about this transaction that made me suspicious? -Remember, the member should never ever be tipped off in any way. We do business with them as we ordinarily would once it is in accordance with our internal policies. -The member should never ever be made to feel like a suspect or criminal. -While we want to do our part to help combat Money Laundering and the Financing of Terrorism, our overarching Company Policy will always be to provide excellent service to members/potential members

6. What makes you Suspicious? Examples • Sudden large deposits, repayments or withdrawals • Transfer of funds from high risk areas • Unusual Borrowing Activity • Deliberately providing none or insufficient data for SOF, or staying just below the limit

7. What makes you Suspicious? Examples • Deliberate efforts to avoid record keeping (for companies) • Activities that are inconsistent with Members’ Line of Business • Shell/Paper Companies • Persons constantly doing business on behalf of a PEP or embassy official

8. What makes you Suspicious? Examples • Unwilling to provide information required • Nervous/Shady behaviour • ANY other situation that made you feel suspicious or uncomfortable

9. Compliance Step 3- Report to the Compliance Officer The following should be reported to the Compliance Officer:- 1) ALL suspicious transactions • These should be communicated over the phone or in person. • The Compliance officer will do the SAR/STR for the FIU. 2) ALL PEPs 3) ALL Foreign Citizens or Residents 4) ALL members with known illegal businesses eg. PH Taxi drivers, scalpers

10. What happens… • If you did your due diligence, know your member and were NOT suspicious? -Move on with the rest of your life • If you reported someone to the Compliance Officer out of suspicion but that person is actually innocent? -Nothing, move on with the rest of your life

11. Recap At ALL times, we maintain a friendly, helpful, member-oriented attitude “ The more successful you and your organization become, the more humble and devoted to your customers you need to be”-Robin Sharma Report to the Compliance Officer where applicable within 5 days Get to know your Member/ Company As yourself if you were suspicious

12. Your Compliance One Pager

13. Questions • Do you understand the 3 Steps of Compliance? • Do you know what to do when there is a suspicious activity? • Do you understand the new forms? • Do you understand the new procedures? (eg. “original seen”, proper address verification, putting your initials after requirements etc.) • When does all of this become effective?