Anti-Money Laundering / Countering the Financing of Terrorism / Countering Proliferation Financing Policy
Kyoto Financial Group, Inc. (the Company) and its subsidiaries (the Group) establish the governance structure and sets the following policies, procedures and approaches in order to comply with the applicable legal and regulatory requirements and obligations to implement appropriate Anti-Money Laundering / Countering the Financing of Terrorism / Countering Proliferation Financing (AML/CFT/CPF) measures for ensuring business adequacy.
- 1.
Management Policy
The Group acknowledges AML/CFT/CPF as a critical management issue and establishes the AML/CFT/CPF framework to respond to emerging regulatory policy and any other relevant affairs in a timely and appropriate manner as an integrated organization.
- 2.
Organizational Framework
The Director in charge of Business Management Division of the Company is appointed as the Anti-Money Laundering Compliance Officer of the Group. The Company coordinates with its subsidiaries to establish a centralized management system and take measures against Money Laundering, and the Financing of Terrorism and Proliferation (ML/TF/PF) across the organization.
- 3.
Risk-Based Approach
In order to effectively prevent ML/TF/PF, the Group identifies and assesses the ML/TF/PF risks to which the Group is exposed in a timely and appropriate manner, and implements appropriate countermeasures designed to mitigate those risks.
- 4.
Customer Due Diligence
The Group conducts verifications at the time of transaction in a timely and appropriate manner, and has in place AML/CFT/CPF framework to implement countermeasures in line with customer attributes. The countermeasures are updated based on the recorded results of the periodic investigation and analysis of customer transactions.
- 5.
Sanctions and Asset Freezing
The Group screens its customers and transactions against applicable sanctions lists. The Group implements appropriate measures to ‘freeze’ accounts, funds, or other assets of designated individuals/entities in which a targeted government or authority has an interest.
- 6.
Reporting of Suspicious Transactions
In accordance with relevant laws and regulations, the Group investigates transactions giving rise to doubts about ML/TF/PF, and promptly reports Suspicious Transaction Reports to the competent authorities as necessary.
- 7.
Correspondent Banking Due Diligence
The Group collects sufficient information related to correspondent banks in order to evaluate and implement appropriate countermeasures commensurate with the ML/TF/PF risks presented by the correspondent banking relationships. The Group prohibits transacting with shell banks and any other counterpart that permit the use of accounts with high anonymity.
- 8.
Training
The Group aims to provide regular and targeted trainings to enhance Group personnel’s understanding of their respective roles and responsibilities, and expertise in carrying out the Group AML/CFT/CPF policies.
- 9.
Monitoring and Testing
The Group aims to continually strengthen the Group AML/CFT/CPF policies, procedures and systems through regular audit conducted by the independent Internal Audit Division.