Anti-Money Laundering and Countering the Financing of Terrorism Policy
- Implementation of the Risk-Based Approach
Our company will appropriately identify and assess the risks of money laundering and terrorist financing that we face, and will take mitigation measures commensurate with those risks.
- Implementation of Customer Due Diligence, etc., at the Time of Transaction
Our company will appropriately implement customer due diligence at the time of transaction, in accordance with laws and regulations.
- Ongoing Customer Management
Our company will conduct filtering based on sanction lists.
Furthermore, our company will understand the risks based on customer attributes and other factors, conduct ongoing transaction monitoring, and perform customer management according to the risks.
- Reporting of Suspicious Transactions and Analysis of Reported Content
Our company will create rules for detecting suspicious transactions, taking into account information such as customer attributes and the circumstances of the transaction, and will conduct transaction monitoring based on these rules.
When our company detects a suspicious transaction, we will promptly report it to the authorities in accordance with laws and regulations.
Furthermore, our company will analyze the content of suspicious transaction reports, review the risk assessment for customer attributes and transaction patterns, and revise the detection rules as necessary.
- Involvement of Management
Our company positions the prevention of money laundering and terrorist financing as one of the important issues in our management strategy, and the management team will correctly recognize the risks and proactively and actively be involved in the establishment of the system and the formulation and implementation of effective risk mitigation measures.
- Chief Administrator
Our company will appoint a Chief Administrator responsible for anti-money laundering and counter-terrorist financing measures, consolidate information related to money laundering with this person, and systematically and accurately implement measures for the prevention of money laundering under the direction of this person.
- Acquisition of Knowledge and Improvement of Awareness of Officers and Employees
Our company will strive to ensure that officers and employees acquire knowledge and improve their awareness regarding the prevention of money laundering and terrorist financing through training and other means.