AMLポリシー

To prevent terrorist financing, money laundering, and illegal use of funds transfer services, remittance clients and members must be identified. The Company shall have the person submit the necessary information and confirm whether the notification is correct based on the prescribed identification documents.

Officers and employees shall be discontinued when they receive remittance requests or applications for member registration from customers who cannot identify themselves. In addition, re-identification shall be carried out in the event of a situation requiring identification again.

In addition, if an officer or employee finds a suspicious transaction, the company must report it to the authorities. The business manual illustrates what kind of transaction is suspicious, but if a suspicious transaction is found or cannot be determined, check with the Compliance Manager immediately.

According to the Foreign Exchange and Foreign Trade Law, it is necessary to confirm the following for each remittance.

• Whether the remittance customer or beneficiary does not fall under economic sanctions such as asset freeze.
• Whether it violates North Korea's trade-related payment regulations. (Payments made by North Korea as a remittance country, etc.)
• Whether it conflicts with regulations on the use of funds in North Korea and Iran (e.g. activities that may contribute to nuclear-related programs in North Korea and Iran, payments that contribute to Iran's supply of large conventional weapons, etc.)

Officers and employees need to check if they fall under the above conditions by system verification and confirm the purpose of remittance. If this is the case, remittance requests and member registration must be declined unless permission issued by the authorities is confirmed.

In addition, it is necessary to check if the remittance customer is applicable to the following:

• Lists of anti-social forces
• Lists of persons subject to economic sanctions such as asset freeze
• PEPs targets (Politically Exposed Persons)
• Lists of OFAC Sanctions (Office of Foreign Assets Control)
• Lists of UN Sanctions

The following examples illustrate the types of transactions that should be paid particular attention to when performing the obligation to report suspicious transactions prescribed in Article 9 of the Act on the Prevention of Transfer of Criminal Proceeds.

Therefore, these cases are references to finding or extracting suspicious transactions during daily transactions, and not all formal matches are suspicious transactions, even if they are not, they are subject to notification.

• Transactions involving customers who provide suspected or unclear information when remittance to a foreign country. Transactions involving customers who provide information about remittance destinations, the purpose of remittance, remittance resources, etc. are not considered reasonable.
• Transactions that are frequent in a short period of time with a large amount of money transferred.
• Transactions involving large remittances for purposes that are not economically rational.
• Transactions carried out by customers based in countries or regions that are not cooperative in AML measures or in countries or regions that issue illicit drugs. Countries and regions designated by the Financial Services Agency as jurisdictions where surveillance should be strengthened.
• Transactions made by customers with persons (including corporations) based in countries/regions or countries/regions that are not cooperative in AML measures.
• Transactions involving customers introduced by persons (including corporations) based in countries/regions or countries/regions that are not cooperative in AML measures.
• Transactions made in counterfeit currency, counterfeit securities, stolen currency, or stolen securities, where the other party to the transaction is suspected of knowing that the currency or securities have been forged or stolen.
• Transactions involving customers who unnaturally emphasize the confidentiality of transactions and customers who have attempted to request, coerce, acquire, etc. not to make a notification.
• Transactions involving a member of a crime syndicate, officials of a crime syndicate, etc.
• Transactions involving customers whose unnatural forms or attitudes, trends, etc. are recognized from the perspective of knowledge, experience, etc.
• Others (transactions that were inquired or reported as being related to criminal proceeds from outside such as public institutions)