Basic Policy on Prevention of Money Laundering and Terrorist Financing

In addition to various laws and regulations in Japan related to Money Laundering etc., the company has established an effective system to prevent Money Laundering etc. in light of international requests such as FATF, to continue making efforts to prevent Money Laundering etc.

In order to prevent Money Laundering etc., the company has formulated and implemented policies, verified and reviewed its effectiveness, and actively involved its management team. The company has appointed an officer to manage Money Laundering etc. and takes the following measures based on three lines of defense.

1st line of defense     Business operation department: Measurements related to prevent Money Laundering etc.
2nd line of defense     Risk management department: Restrain and support business operation department
3rd line of defense     Internal audit department: Verify company-wide effectiveness from an independent standpoint

Based on risk-based approach, the company identifies and assesses the risks related to Money Laundering etc., on a regular or occasional basis.

In order to mitigate the risks identified and assessed based on the provision of “3. Risk Assessment”, the company implements rules and regulations, such as customer management, filtering, transaction monitoring, records retention, submitting suspicious transactions, correspondent relationship management, and other risk reduction measures.

The company thrives to deepen knowledge and understanding through trainings and other methods, in order to equip its executives and employees with expertise and suitability in AML which is required for their roles.

The company conducts company-wide test of the effectiveness of its efforts to prevent Money Laundering etc. and will make continuous improvements based on the test results.