August 12, 2021
The Iyo Bank, Ltd.
Basic Policies for Anti-Money Laundering and Combating the Financing of Terrorism
The Iyo Bank, Ltd. (hereinafter “the Bank”) positions the prevention of money laundering andfinancing of terrorism (hereinafter “Money Laundering, etc.”) as an important management issue,
taking into consideration the fact that this is a key responsibility of the Bank as a financial institution
with a public mission, and hereby declares that as we execute business operations, we will establish
internal management systems aimed at preventing Money Laundering, etc.
1. Organizational Systems(1) The Board of Directors of the Bank recognizes and understands the importance ofcountermeasures to prevent Money Laundering, etc., and shall take the initiative in focusing onsuch countermeasures.
(2) The Bank shall determine persons responsible for countermeasures to prevent Money
Laundering, etc., and a department for the oversight thereof, thus establishing centralizedmanagement systems, and the organization as a whole shall tackle Money Laundering, etc., in across-departmental manner, based on cooperation between related departments.
2. Risk Management Based on a Risk-Based Approach(1) The Bank shall execute appropriate risk management based on a risk-based approach against
the risk of Money Laundering, etc., including effectively utilizing IT systems and various typesof data to identify and evaluate risk, and implement risk mitigation measures for each type of risk.
In particular, the Bank shall establish systems for preventing Money Laundering, etc., byimplementing appropriate confirmation measures, etc., for foreign remittances ordered andreceived, export and import transactions, ship financing, and other types of transaction withoverseas.
(2) The Bank shall implement appropriate transaction monitoring and screening, and establish
systems for accurately detecting, monitoring, and analyzing suspicious customers andtransactions.
3. Compliance with Laws and Regulations, etc., and Appropriate Customer Due Diligence
Measures
The Bank shall comply with various laws and regulations, etc., for countermeasures to prevent
Money Laundering, etc., and shall appropriately implement identification and verification at thetime of transactions, and other necessary customer due diligence measures.
4. Suspicious Transaction Reporting and Asset Freezing Measures
Pursuant to various laws and regulations, etc., the Bank shall establish systems to reportsuspicious transactions and appropriately implement measures against persons whose assets havebeen frozen, etc.

5. Correspondent Bank Management
The Bank shall conduct regular investigations of correspondent banks, in order to verify andmonitor their systems for preventing Money Laundering, etc. In addition, the Bank shall not enter
into or maintain correspondent banking arrangements if a correspondent bank is a shell bank, orpermits transactions with shell banks.
6. Conducting Training, etc.
The Bank shall conduct necessary and appropriate training, etc., for all officers and employees,
in accordance with their roles, on an ongoing basis, and the organization as a whole shall takesteps to enhance understanding of countermeasures to prevent Money Laundering, etc., andmaintain and enhance the expertise and qualifications of officers and employees.
7. Anti-bribery and Anti-corruption
The Bank shall strive to ensure that all officers and employees acquire a high level ofprofessional ethics, and shall prohibit bribery as well as entertainment and gift-giving, etc. thatexceed a level considered reasonable under the generally accepted view by society in accordancewith the purport of various laws and regulations, etc.
8. Evaluation of Effectiveness and Validity
The Bank shall regularly evaluate the effectiveness and validity of all initiatives related tocountermeasures to prevent Money Laundering, etc., make improvements as necessary, and takesteps to enhance and strengthen internal management systems across the Bank as a whole, on anongoing basis.