Exhibit 14

                   SANTA FE FINANCIAL CORPORATION
                          CODE OF ETHICS
                               FOR
                     SENIOR FINANCIAL OFFICERS



This Code of Ethics applies to Santa Fe Financial Corporation's ("Santa Fe"
or the "Company") Senior Financial Officers.  "Senior Financial Officers"
shall include the principal executive officer, the principal accounting
officer or controller, or persons performing similar functions, including
Santa Fe's President and Chief Executive Officer, Chief Financial Officer,
Treasurer, Controller, Vice President, and such other individuals as
determined from time to time by the Audit Committee of the Company for
purposes of this Code of Ethics.  The Company expects all employees, in
carrying out their job responsibilities, to act in accordance with the
highest standards of personal and professional integrity, to comply with all
applicable laws, and to abide by Santa Fe's other corporate policies and
procedures adopted from time to time by the Company. This Code of Ethics
supplements the foregoing with respect to all Senior Financial Officers.

Santa Fe's Senior Financial Officers will:

    1. Engage in and promote honest and ethical conduct, acting with
integrity and exercising at all times their best independent judgment;

    2. Avoid actual or apparent conflicts of interest between personal and
professional relationships and disclose to the Company's Audit Committee and
counsel any material transaction or relationship that reasonably could be
expected to give rise to such a conflict;

    3. Produce full, fair, accurate, timely and understandable disclosure in
reports and documents that Santa Fe files with, or submits to, the Securities
and Exchange Commission and in other public communications made by Santa Fe;

    4. Comply with applicable governmental laws, rules and regulations, as
well as the rules and regulations of self-regulatory organizations of which
Santa Fe is a member;

    5. Maintain the confidentiality of Company information, except when
authorized or otherwise required to make any disclosure, and avoid the use of
any Company information for personal advantage;

    6. Promote ethical and honest behavior among employees under your
supervision; and

    7. Promptly report any possible violation of this Code of Ethics to the
Audit Committee and the Company's counsel.

All Senior Financial Officers are prohibited from directly or indirectly
taking any action to coerce, manipulate, mislead or fraudulently influence
Santa Fe's independent public accountant engaged in the performance of an
audit or review of the financial statements of the Company for the purpose of
rendering the financial statements of Santa Fe misleading.

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The Audit Committee of the Board of Directors shall approve any waiver or
amendment of this Code of Ethics, and any such waiver or amendment shall be
disclosed promptly as required by law and SEC regulations.

All Senior Financial Officers will be held accountable for their adherence to
this Code of Ethics. Failure to observe the terms of this Code of Ethics may
result in disciplinary action, up to and including termination of employment.
Violations of this Code of Ethics may also constitute violations of law, and
may result in civil and criminal penalties for the individual, his or her
supervisor and/or Santa Fe.

If a Senior Financial Officer has any questions regarding the best course of
action in a particular situation, he or she should promptly contact the
Chairman of the Audit Committee or the Company's counsel. An individual may
choose to remain anonymous in reporting any possible violation of this Code
of Ethics.


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