Anti-Money Laundering Policy

Internal Regulations Concerning Identity Verification and Suspicious Transaction Reporting

 

(Purpose)

Article 1

            In view of the fact that the establishment of an internal management system for identity verification and reporting about suspicious transactions (both hereinafter collectively referred to as “Identity Verification, etc.”) under the Law on Prevention of Transfer of Criminal Proceeds (Law No. 22 of 2007; hereinafter referred to as the “Law on Criminal Proceeds”) has great significance in preventing the abuse of financial services for organized crimes, and for securing trust in the Japanese financial system, the purpose of these Regulations is to set forth the matters to be noted with respect to Identity Verification, etc.

 

(Department Responsible for Identity Verification, etc., and Person in Charge of Legal Compliance)

Article 2

1.         The department responsible for identity verification shall be the Customer Service Department.

2.         The department responsible for reporting about suspicious transactions shall be the Customer Service Department.

3.         The general manager of the Customer Service Department shall be the person in charge of legal compliance with respect to Identity Verification, etc.

 

(Establishment of Management System)

Article 3

1.         Upon the occurrence of a problem with Identity Verification, etc., employees of the department from which the problem has originated shall promptly report to and consult with the Customer Service Department, and the Customer Service Department shall manage the problem in a unified way.

2.         The Customer Service Department shall have in place a system under the provisions of these Regulations to respond to problems related to Identity Verification, etc.

3.         Taking into account the nature, significance and other factors of the problem, the Customer Service Department shall, if necessary, report the problem to the Business Integration Division, and consider how to respond to the problem jointly with the Business Integration Division.

 

(Employee Recruitment Policy)

Article 4

            We shall employ, as employees, those who understand the significance of Identity Verification, etc., and are able to appropriately conduct Identity Verification, etc., under these Regulations.

 

(Correspondent Agreement)

Article 5

1.         When a correspondent agreement is executed for the provision of our money transfer service, the Customer Service Department shall, with respect to the other party of the correspondent agreement (hereinafter referred to as the “Correspondent Entity”), report to the Business Integration Division its user base, description of operations, local supervisory system, the fact that it is not a fictitious bank (a so-called shell bank), and that it has not conducted or does not conduct transactions with a fictitious bank, and other facts, and shall check whether it is an appropriate Correspondent Entity together with the Business Integration Division.

2.         When the correspondent agreement is renewed or otherwise extended, the Customer Department shall follow the procedures under the preceding paragraph.

 

(Preparation of Internal Manual)

Article 6

            In connection with Identity Verification, etc., the Customer Service Department shall prepare a manual for Identity Verification, etc., (hereinafter referred to as the “Manual for Identity Verification, etc.”) which shall set forth the actions to be taken, including, without limitation, the method of identity verification, preparation and storage of records, reporting method and periodic checking.

 

(Verification of Identity)

Article 7

1.         When identity verification is necessary as provided in the Manual for Identity Verification, etc., employees shall verify the identity by the method set forth in the Manual for Identity Verification, etc.

2.         If the user does not consent to the identity verification under paragraph 1 above, employees shall not render any money transfer service to such user.

 

(Preparation and Storage of Identity Verification Records)

Article 8

            The Customer Service Department shall prepare and store identity verification records related to identity verification under Article 7 above by the method of preparation and storage of identity verification records set forth in the Manual for Identity Verification, etc.

 

(Preparation and Storage of Transaction Records)

Article 9

            The Customer Service Department shall prepare and store transaction records related to identity verification under Article 7 above by the method set forth in the Manual for Identity Verification, etc.

 

(Suspicious Transaction Reporting)

Article 10

1.         If an employee detects a suspicious transaction set forth in the Manual for Identity Verification, etc., or any other matter which requires internal reporting by following the method based on the Manual for Identity Verification, etc., the employee shall immediately report the transaction to the Customer Service Department in accordance with the internal reporting procedures applicable to suspicious transactions set forth in the Manual for Identity Verification, etc.

2.         If, pursuant to the Manual for Identity Verification, etc., the Customer Service Department deems it necessary to file with the Financial Services Agency a report about the transaction reported under paragraph 1 above, the Customer Service Department shall file the report therewith by the method set forth in the Manual for Identity Verification, etc.

3.         When the Customer Service Department receives a report under paragraph 1 above, the Customer Service Department shall prepare a record of the contents of the report and maintain the same.

4.         When the Customer Service Department receives a report under paragraph 1 above, other than the filing of a report about the suspicious transaction, the Customer Service Department shall identify the cause of the problem, and shall appropriately respond to the situation by means of a hearing with the user, further checking, or other means.

 

(Further Verification of Identity)

Article 11

            If a doubt arises as to the authenticity or appropriateness of the identity verification information previously obtained, or if there is a possibility that the other party of the transaction pretends to be the person in whose name the transaction is conducted, or in other such cases, the Customer Service Department shall request the resubmission of the identity verification document for further identity verification by such method of identity verification as is set forth in the Manual for Identity Verification, etc.

 

(Suspension of Use)

Article 12

            If an investigative authority, etc., provides information to the effect that an exchange transaction related to our money transfer service has been used for fraud or other criminal act, or if there is a possibility that exchange transaction has been involved in a criminal act, the Customer Service Department shall, if necessary, take the following actions with the consent of the Business Integration Division and the management.

(1)   Action to promptly suspend the exchange transaction suspected to be used for the criminal act

(2)   Action to suspend the payment of money to the person who has executed an account opening agreement, etc., and is suspected of using the agreement for the criminal act

 

(Investigation Commission, etc.)

Article 13

            When, with respect to an unauthorized use of our money transfer service, the court commissions us to investigate or we receive an inquiry, etc., under the Attorney Law, the Customer Service Department shall appropriately respond to the same, while paying attention to the obligation of confidentiality.

 

(Thorough Dissemination)

Article 14

1.         In order to appropriately conduct Identity Verification, etc., the Business Integration Division shall thoroughly disseminate the relevant information to our officers and employees.

2.         At the time of such thorough dissemination, the Business Integration Division shall pay attention so that the officers and employees in charge to whom the information shall be disseminated can accurately understand the following matters.

(1)   Method of Identity Verification, etc., and the method of preparation and storage of identity verification records, etc.

(2)   Method of reporting in case of occurrence of a suspicious transaction, etc.

(3)   Other matters necessary for Identity Verification, etc.

3.         Such thorough dissemination to our officers and employees shall be implemented by the following methods, and after such implementation, a test shall be conducted to check the depth of understanding.

(1)   Implementation of internal training, etc.

(2)   Notification about the contents of internal rules, etc., in writing, via email, or by other means

(3)   Method of making internal rules, etc., accessible on the internal information bulletin board

(4)   Other methods determined by the Customer Service Department

4.         The thorough dissemination set forth in the preceding paragraph shall be implemented at least three (3) times a year.

 

(Validation of Operations in Connection with Identity Verification, etc.)

Article 15

1.         The general manager of the Business Integration Division shall, with respect to operations subject to these Regulations, check whether identity verification and the filing of reports about suspicious transactions under the Manual for Identity Verification, etc., are appropriately implemented.

2.         The Business Integration Division shall, approximately once every four (4) months, report to the management the checked details of such operations conducted by using the method mentioned in the preceding paragraph. However, this shall not apply if a prompt report is required depending on each individual situation.

 

 

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