（Translation Date: April 2023）

依頼者の本人特定事項等の確認及び記録保存等に関する規則（平成二十四年十二月二十日規則第百五十四号）
Regulations Concerning Verification of Client Identity and Retention of Records(Adopted on December 20, 2012: Regulations No. 154)

Amended on January 22, 2016
Amended on May 6, 2016
Amended on September 16, 2016
Amended on March 16, 2017
Amended on December 21, 2017
Amended on August 24, 2018
Amended on October 24, 2018
Amended on January 17, 2019
Amended on November 22, 2019
Amended on December 20, 2019
Amended on August 20, 2020
Amended on January 22, 2021
Amended on April 16, 2021
Amended on June 18, 2021
Amended on December 17, 2021
Amended on September 15, 2022
Amended on March 16, 2023

Article 1. (Purpose)
1. These Regulations are intended to stipulate the matters based on the delegation pursuant to theprovisions of Paragraph 4, Article 11 and Article 13 of the Rules Concerning Verification of Client
Identity and Retention of Records (No. 95 of the Federation Rules; hereinafter referred to as the“Rules”).
2. The terms used in these Regulations shall have the meanings used in the Rules. Furthermore, themeanings of the terms listed in the upper column of the attached table shall be as defined in the lower
column of the same table.

Article 2. (Amount of Assets Relating to Asset Management Acts That Require Client Identity
Verification)
The amount prescribed in Paragraph 1 of Article 2 of the Rules shall be 2,000,000 JPY.

Article 2-2. (Methods of Verification of Client Identity)
1. The method stipulated in Paragraph 1 of Article 2 of the Rules, those pertaining to the matters listed
in Item 1 of the same Paragraph shall be any of the methods set forth in the following each item.
(1) If the client is a natural person, any of the method set forth below:a) Method in which Identity Verification Documents of a Natural Person With Photo are presented;b) Method in which Identity Verification Documents of a Natural Person (except Identity Verification
Documents of a Natural Person With Photo) are presented and also Engagement Agreement addressed tothe home of the client stated in such Identity Verification Documents of a Natural Person are sent as
Mails Not Requiring Forwarding by Registered Mails;c) Method in which two types of Social Insurance Certificates and Pension Handbook are presented;d) Method in which Social Insurance Certificates and Pension Handbook and Identity Verification
Documents of a Natural Person apart from the foregoing (except Identity Verification Documents of a
Natural Person With Photo or Social Insurance Certificates and Pension Handbook) or Supplementary
Documents are presented;e) Method in which Social Insurance Certificates and Pension Handbook are presented, and also Identity
Verification Documents of a Natural Person apart from the foregoing (including the copy thereof) or
Supplementary Documents (including the copies thereof) are received;f) Method in which identification image information (meaning the image information of the client's face
and the Identity Verification Documents of a Natural Person With Photo taken by the client using thesoftware, where the image information related to the Identity Verification Documents of a Natural
Person With Photo allows the verification of the name, address, and date-of-birth recorded on the
Identity Verification Documents of a Natural Person With Photo, the photo attached to the Identity
Verification Documents of a Natural Person With Photo, and the thickness and other features of the
Identity Verification Documents of a Natural Person With Photo.) is transmitted, with using software
provided by the Attorney;g) Method in which identification image information (meaning image information of the client's facetaken by the client using the software) is transmitted with using software provided by the Attorney, andalso information recorded in a semiconductor integrated circuit (referring to a semiconductor integrated
circuit as stipulated in Paragraph 1 of Article 2 of the Act on the Circuit Layout of a Semiconductor
Integrated Circuit (Act No. 43 of 1985), the same applies hereinafter.) embedded in the client’s Identity

Verification Documents of a Natural Person With Photo (limited to those with a built-in semiconductor
integrated circuit that records information such as name, address, date-of-birth and photo) is transmitted.
h) Method in which Identity Verification Documents of a Natural Person are presented, or information
recorded in a semiconductor integrated circuit embedded in the client’s Identity Verification Documentsof a Natural Person (limited to those with a built-in semiconductor integrated circuit that records
information such as name, address and date-of-birth) is transmitted, or identification image information(meaning the image information of the client's Identity Verification Documents of a Natural Person(limited to those issued or provided only once) taken by the client using the software provided by the
Attorney, where the image information related to the Identity Verification Documents of a Natural
Person allows the verification of the name, address and date-of-birth recorded on the Identity
Verification Documents of a Natural Person and the thickness and other features of the Identity
Verification Documents of a Natural Person.) is transmitted (the image information is limited to betransmitted by using software provided by the Attorney), and also Engagement Agreement addressed tothe home of the client stated in or recorded on the Identity Verification Documents of a Natural Person
are sent as Mails Not Requiring Forwarding by Registered Mails; ori) Method in which copies of two types of Identity Verification Documents of a Natural Person with theclient's current address are sent, or a copy of Identity Verification Documents of a Natural Person and
Supplementary Documents (including those of a person living with the client in the case of public utility
receipts, and meaning the Supplementary Documents and other Supplementary Documents (limited tothose of the client) when the client's current address is not stated in the Identity Verification Documentsof a Natural Person) or the copy thereof are sent, and also Engagement Agreement addressed to thehome of the client stated in the Identity Verification Documents of a Natural Person or the
Supplementary Documents (meaning the address stated in the Supplementary Documents or the copy
thereof when the client's current address is not stated in the copy of Identity Verification Documents of a
Natural Person) are sent as Mails Not Requiring Forwarding by Registered Mails.
(2) If the client is a juridical person, any of the method set forth below:a) Method in which Identity Verification Documents of a Juridical Person are presented;b) Method in which Identity Verification Documents of a Juridical Person (including a copy thereof) arereceived and also Engagement Agreement addressed to the head office or the principal place of businessof the client stated in such Identity Verification Documents of a Juridical Person are sent as Mails Not
Requiring Forwarding by Registered Mails;c) Method in which declarations from a client regarding the client's name and address of head office or
the principal place of business are received, and also the Attorney requests Government Authority toissue or to provide and receives Identity Verification Documents of a Juridical Person from it. (Inaddition to the aforementioned method, Engagement Agreement addressed to the head office or the
principal place of business of the client are sent as Mails Not Requiring Forwarding by Registered Mails
when the Attorney receives the declaration without a face-to-face meeting with natural person actually
instructing Attorneys (hereinafter referred to as the “Natural Person Concerned”) (limited to those whoare not registered as officers with the authority to represent the client when the a certificate of registeredmatters related to the registration of the establishment of a corporation is issued or provided as Identity
Verification Documents of a Juridical Person.).);d) Method in which declarations from a client regarding the client's name and address of head office or
the principal place of business are received, and also registration information from designatedcorporations as stipulated in Paragraph 2 of Article 3 of the Act on Provision of Registration throughTelecommunication Lines (Act No. 226 of 1999) (referring to registration information defined in
Paragraph 1 of Article 2 of the same Act; hereinafter the same) is transmitted. (In addition to theaforementioned method, Engagement Agreement addressed to the head office or the principal place ofbusiness of the client are sent as Mails Not Requiring Forwarding by Registered Mails when the
Attorney receives the declaration without a face-to-face meeting with Natural Person Concerned (limited
to those who are not registered as officers with the authority to represent the client when the a certificate
of registered matters related to the registration of the establishment of a corporation is issued orprovided as Identity Verification Documents of a Juridical Person.).); ore) Method in which declarations from a client regarding the client's name and address of head office or
the principal place of business are received, and also the Attorney confirms the client's name and addressof head office or the principal place of business as published under the provisions of Paragraph 4 of
Article 39 of the Act on the Use of Numbers to Identify a Specific Individual in Administrative
Procedures (Act No. 27 of 2013). (In addition to the aforementioned method, Engagement Agreement
addressed to the head office or the principal place of business of the client are sent as Mails Not
Requiring Forwarding by Registered Mails when the Attorney receives the declaration without aface-to-face meeting with Natural Person Concerned.)(3) If a client is introduced by another business operator, and such another business operator has verified
the identity verification in accordance with the provisions of laws and regulations, and the data for suchverification is readily available to the Attorneys without delay, the method in which the Attorneys obtaindata concerning the identity verification from such another business operator.
(4) If the purpose of the instruction is not likely involving a transfer of criminal proceeds, in view of theattributes of the client, business relationship with the client, and the details of the instruction, a method
in which Identity Verification Documents of a Natural Person (including a copy thereof) or Identity
Verification Documents of a Juridical Person (including a copy thereof) are presented or sent; or(5) If verification of identity by one of the methods stated in Item 1 and Item 2 may hinder an
acceptance of instructions for legitimate legal matters, a method specified in each of the following (a) or(b).
(a) When Attorneys may not verify the identity using methods stated in Items 1 or 2 or may not send
Mail Not Requiring Forwarding by Registered Mail, because the client is abroad, a method that abusiness operator in that foreign country uses for verifying identity of clients or otherwise a method thatis equally reliable as the method set forth in Items 1 or 2; and(b) When a client is in custody at a penal detention facility due to arrest, detention, or serving a sentenceor other reasons, a method of receiving delivery or access to documents in which the court indicates thebasis for body restraint of the client, such as a copy of detention warrant and written judgment, andwhich states identity of the client.
2. The methods stipulated in Paragraph 1 of Article 2 of the Rules, those pertaining to the matters listed
in Item 2 through 4 of the same Paragraph shall be the methods that is sufficient for Attorneys making
judgments for the matters listed in items 2 through 4 of the same paragraph, such as a method in which
declarations from a client.

Article 2-3. (Beneficial Owner)
The person stipulated in Paragraph 1 of Article 2 of the Rules shall be a natural person who is in a
relationship that allows ultimately own or control its business management with taking into account thefollowing circumstances, who Attorneys determine (hereinafter referred to as "Beneficial Owner").
(1) Whether or not there is a natural person who is deemed to have a controlling influence on thebusiness activities of the company or Entities through holding voting rights, such as having more than
one-fourth of the total voting rights of the company or Entities.
(2) In cases where it is impossible to determine the Beneficial Owner of the company or Entities due tothe circumstances stipulated in the preceding item, whether or not there is a natural person who isdeemed to have a controlling influence on the business activities of the company or Entities throughinvestment, loans, transactions, or other relationships.
(3) In cases where it is impossible to determine the Beneficial Owner of the company or Entities due tothe circumstances stipulated in the preceding two items, whether or not there is a natural person who isdeemed to have a controlling influence on the business activities of the company or Entities throughrepresentative authority or other business execution authority.

Article 3. (Special Provisions for Identity of Client that is a Natural Person)
Such circumstances that are stipulated in Item 1 of Paragraph 1 of Article 2 of the Rules shall be thecases set forth in each following item below and such matters that are stipulated in the said item shall be
the matters as provided for in respect of the relevant case:(1) When Attorneys find it impossible or extremely difficult to prove their address or data of birth
because the client who is a natural person is abroad: name, passport number and such other informationthat a business operator in that foreign country confirms to identify the client; and(2) When a client who is a natural person is in custody in a penal detention facility due to having beenarrested, taken into detention, serving a sentence or other reasons: items stated by the courts in order to
identify the client in a document that indicates the grounds for the client’s custody.

Article 4. (Methods of Verification of Source of Wealth and Source of Funds)
The method stipulated in Article 3 of the Rules shall be the methods that is sufficient for Attorneys
making judgments for the client's source of wealth and source of funds, such as a method in which
declarations from a client.

Article 5. (Persons Equivalent to Those Who Occupy Important Positions or Countries not Having
Adequately Established a System for Prevention of Transfer of Criminal Proceeds)
1. Persons provided for in Item 3 a) of Article 3 of the Rules shall be such persons who had been the headof a foreign state or who had occupied important position in the government of a foreign state, and areconsidered as having high risks of a transfer of criminal proceeds, taking into consideration the degree of
influence that may be given by the said person as well as the relevance between the position assumed bysaid person in the past and his/her current duties.
2. Countries and regions stipulated in Item 4 of Article 3 of the Rules are Iran and North Korea.

Article 6. (Method of Identity Verification for Natural Persons)
1. The method stipulated in Paragraph 1 of Article 4 of the Rules shall be the method set forth below:(1) The method that confirms the Natural Person Concerned has possessed a power of attorney or any
other document attesting that the Natural Person Concerned has been engaged in Asset Management
Acts or Transactions for the client;(2) The method that confirms the Natural Person Concerned has been registered as an officer with theauthority to represent the client; or(3) The method that confirms the authority of the Natural Person Concerned by means of making aphone call to the head office, the principal place of business or business place of the client.
2. The method stipulated in Paragraph 2 of Article 4 of the Rules shall be a method that verifies theidentity of the Natural Person Concerned according to the methods stated in any of each item of

Paragraph 1 (excluding Item 2, and the same shall apply in the following paragraph) of Article 2-2 andstated in Paragraph 2 of Article 2-2; provided, however, that Attorneys may send the Engagement
Agreement to the head office, business place, or other location where the client concerned works insteadof the home of the Natural Person Concerned.
3. The method stipulated in Paragraph 4 of Article 4 of the Rules shall be a method that verifies theidentity of the Natural Person Concerned according to the methods stated in any of each item of
Paragraph 1 of Article 2-2; provided, however, that Attorneys may send the Engagement Agreement to
the head office, business place, or other location where the client concerned works instead of the homeof the Natural Person Concerned.

Article 7. (Entities Whose Identities are Confirmed)
Entities stipulated in Item 3 of Paragraph 3 of Article 4 of the Rules shall be as follows.
(1) Incorporate administrative agencies;(2) Juridical persons in which a national or local government has contributed more than 50% of capital,
funds, or other money pursuant thereto;(3) Foreign governments, foreign governmental institutions, foreign local governments, foreign central
banks or international institutions of which Japan is a member; and(4) Entities that are listed on or registered with stock exchanges that trade securities (excluding markets
in countries and regions provided for in Paragraph 2 of Article 5).

Article 8. (Details of Verification Records)
Details stipulated in the provisions of Paragraph 1 of Article 5 of the Rules shall be as follows.
(1) Name of the person that conducted the Client Identity verification and other matters that are
sufficient to identify such person; and(2) Measures adopted in order to confirm identity and the date and time at which Identity Verification
Documents are presented.
(3) Purpose of the instruction, and the method of verification thereof.
(4) Occupation or nature of the business of the client, and the method of verification thereof.
(5) In the case where the client is a company or Entities, the identity of the Beneficial Owner and therelationship between the Beneficial Owner and the client, as well as the method of verification thereof.
(6) In the case where the verification of source of wealth and source of funds was conducted, the methodof verification thereof.

Article 8-2. (Documents including Other Materials to Retain)

The documents including other materials stipulated in Paragraph 1 of Article 5 and Paragraph 3 ofArticle 8 of the Rules shall be the following:(1) Copy of the document presented by the client(2) Original or copy of the document sent or submitted by the client(3) Information received from the client or a copy thereof(4) Documents, information or public matters, those are obtained by Attorneys through the methods
from (c) to (e) of Item 2 of Paragraph 1of Article 2-2, or copies thereof

Article 9. (Details of Transaction Records)
Details stipulated in the provisions of Paragraph 2 of Article 5 of the Rules shall be as follows.
(1) Matters in order to search Client Identity verification records;(2) Date(s) of the Asset Management Acts or Transactions(3) Type(s) of the Asset Management Acts or Transactions(4) Value of property relating to the Asset Management Acts or Transactions(5) In case the Asset Management Acts or Transactions involve a transfer of property, name(s) of thetransferring entity and the receiving entity (meaning the initial transferring entity and the final receiving
entity relating to such transfer of property which is known to the Attorneys who carry out a part of thetransaction, act, or procedures relating to such transfer of property, and the same shall apply hereinafter)and such other matters that are sufficient to identify the transferring entity and the receiving entity.

Article 10. (Measures to Ensure Implementation of Preventive Measures)
Measures provided for in Item 5 of Article 9 of the Rules shall be measures set forth below:(1) Review of Asset Management Acts or preparation for or carrying out of Transactions that the
Attorneys conduct (including those utilizing new technologies and other new forms thereof) andanalyzing the same, and using the results of such investigation and analysis to change the measures asnecessary.
(2) Collection, sorting out and analysis of such information that is necessary to implement Measures for
Identity Verification, taking into consideration the contents of National Risk Assessment-Follow-up
Report and the contents of Risk Assessment of Money Laundering in Legal Practice formulated by theJapan Federation of Bar Associations.
(3) Continuous and careful examination of the verification records and transaction records taking into
consideration the result of the review and analysis of Item 1.
(4) When Attorneys collect, sorting-out and analyze information pursuant to Item 2 with respect to AssetManagement Acts or preparation for or carrying out of Transactions that fall under each item of Article

3 of the Rules, preparing for a document stating the results thereof and keeping them together with theverification records and transaction records.
(5) Conducting an audit necessary for adequate implementation of Measures for Identity Verification.

Article 11. (Form of Annual Report)
1. The form stipulated in Paragraph 4, Article 11 of the Rules shall be the appended form or such otherform that has nor altered the matters to be reported and that is approved by the Federation.
2. The attachment stipulated in Paragraph 4, Article 11 of the Rules shall be materials to make prima
facie showing the reason with respect to Attorneys who have not practiced law during the previous fiscal
year due to reasons listed below (as to legal profession corporations, registered foreign legal profession
corporations and attorney at law / registered foreign lawyer joint corporations, meaning the reasons
pertaining to their members):(1) Childbirth(2) Childcare(3) Disease(4) Injury

Article 12 (Method for Submitting Annual Report)
The submission method in Paragraph 4, Article 11 of the Rules shall be methods listed below:(1) Physical delivery;(2) Posting;(3) Transmission by facsimile;(4) Website; and(5) Transmission via e-mail.

Supplementary Provisions
1. These Regulations shall come into force as from March 1, 2013.
2. When a disaster occurs, in light of the damages caused by such disaster, notwithstanding theprovisions of Items 5 of Paragraph 1 of Article 2-2, as a temporary measure until identity
verification using methods stated in Items 1 or 2 of Paragraph 1 of Article 2-2 becomes possible, acase when the client’s being a person who resides in, or has the head office or principal place ofbusiness in an area of municipality where the Disaster Relief Act (Act No.118 of 1947) was applied
for such disaster, and special provisions for identity verification method provided by the Ordinancefor Enforcement of the Act on Prevention of Transfer of Criminal Proceeds (Ordinance of theCabinet Office, the Ministry of Public Management, Home Affairs, Posts and Telecommunications,
the Ministry of Justice, the Ministry of Foreign Affairs, the Ministry of Health, Labour and Welfare,the Ministry of Agriculture, Forestry and Fisheries, the Ministry of Economy, Trade and Industry,
the Ministry of Land, Infrastructure and Transport No. 1, 2008) are taken as a temporary measure
until identity verification using methods stated in Article 6 of the above ordinance shall be deemed
to be a case stipulated in Items 5 of Paragraph 1 of Article 2-2, and the method of receiving a reportfrom a natural person if the client is a natural person, or from a representative, agent, or employeeof the juridical person who made the request and performs other matters if the client is a juridical
person (hereinafter referred to as “Method of Identity Verification by Reporting”) shall be deemed
to be the method stipulated in Item 5 of Paragraph 1 of Article 2-2. In such a case, Attorneys shallconduct Identity Verification for such client using the method stipulated in Item 1 and Item 2 ofParagraph 1 of Article 2-2 without delay when it becomes possible to conduct identity verification
using the method stipulated in Item 1 and Item 2 of Paragraph 1 of Article 2-2.
3. Attorneys shall, when conducting Identity Verification by Reporting and reviewing the purpose of
instruction stipulated in Paragraph 1 of Article 6 of the Rules, or the purpose of custody stipulated
in Paragraph 1 of Article 8 of the Rules, considering that identity verification cannot be conductedusing Identity Verification Documents, perform more careful review on whether the purpose of such
request or custody relates to transfer of criminal proceeds, such as by sufficiently scrutinizing thereason for such request or custody and other circumstances.

Supplementary Provisions (Amended on January 22, 2016)
The amended provisions of Article 3 through Article 5, Paragraph 1 of Article 6, and Article 10 (newly
established) shall become effective on the date of enforcement of the Act to Partially Amend the Act on
the Prevention of Transfer of Criminal Proceeds (Act No. 117 of 2014). (To be enforced as of October 1,
2016 under Cabinet Order of 337 of 2015)

Supplementary Provisions (Amended on May 6, 2016)(Effective Date)
1. The amended provisions of the supplementary provisions shall become effective on May 6, 2016 andbecome applicable from April 22, 2016.
(Interim Measures)
2. Concerning application of Paragraph 2 of the Supplementary Provisions for the Regulations Concerning
Verification of Client Identity and Retention of Records after amendment by these amended provisions
until the previous day of the date of enforcement of partial amendment (resolved at the Board of Directors

on January 22, 2016) of the Regulations Concerning Verification of Client Identity and Retention ofRecord (Regulations No. 154), “Items 1 and 2 of Paragraph 3 of Article 2 of the Rules” shall be replacedwith “Items 1 through 3 of Paragraph 3 of Article 2 of the Rules” and “Item 5 of Paragraph 3 of Article 2of the Rules” shall be replaced with “Item 4 of Paragraph 3 of Article 2 of the Rules”.

Supplementary Provisions (Amended on September 16, 2016)
The amended provisions of Item 4 of Article 7 shall become effective on October 1, 2016.

Supplementary Provision (Amended on March 16, 2017)
Amended provisions of the Supplementary Provision shall become effective on April 1, 2017.

Supplementary Provision (Amended on December 21, 2017)
Amended provisions of Paragraph 1, Article 1, Article 11 (newly established), Article 12 (newly
established) and appended form (newly established) shall become effective on January 1, 2018.

Supplementary Provisions (Amended on August 24, 2018)
The amended provisions of the supplementary provisions shall become effective on August 24, 2018
and become applicable from July 13, 2018.

Supplementary Provisions (Amended on October 24, 2018)
The amended provisions of the supplementary provisions shall become effective on October 24, 2018
and become applicable from September 14, 2018.

Supplementary Provisions (Amended on January 17, 2019)
The amended provisions of the Appended Form shall be effective as of January 17, 2019.

Supplementary Provision (Amended on November 22, 2019)
The amended provisions of Paragraph 4 and 5 of the supplementary provisions shall become effective on
November 22, 2019 and become applicable from October 18, 2019.

Supplementary Provision (Amended on December 20, 2019)
The amended provisions of the Appended Form shall be effective as of December 20, 2019.

Supplementary Provision (Amended on August 20, 2020)

The amended provisions of Paragraph 5 and 6 of the supplementary provisions shall become effective on
August 20, 2020 and become applicable from July 10, 2020.

Supplementary Provision (Amended on January 22, 2021)
The amended provisions of Paragraph 2 through 6 of the supplementary provisions shall become
effective on January 22, 2021

Supplementary Provision (Amended on April 16, 2021)
The amended provisions of Paragraph 2 of the supplementary provisions shall become effective on April
16, 2021

Supplementary Provision (Regulations No. 200 of June 18, 2021 (partially amended on September 15,
2022)
Regulations concerning Establishment of Regulations in line with partial amendment to the Act on
Special Measures concerning the Handling of Legal Services by Foreign Lawyers pertaining to thefoundation of attorney at law / registered foreign lawyer joint corporations (amended Article 11, Form)
These Regulations shall become effective on the date of enforcement of the provisions of Article 2 of the
Act on the Amendment Part of the Act on Special Measures concerning the Handling of Legal Services
by Foreign Lawyers (Act No. 33 of 2020).
(To be enforced as of November 1, 2022 under Cabinet Order of 41 of 2022)

Supplementary Provisions (Amended on December 17, 2021)
The amended provisions of the Appended Form shall be effective as of December 17, 2021.

Supplementary Provisions (Amended on March 16, 2023)
1. The amended provisions of the title, Article 1, headings of Article 2, Article 2-2 through Article 4,
Article 6 Paragraph 2 and Paragraph 3 (newly established), Article 8, Article 8-2 (newly established),
Item 1 of Article 9, item 1 and 2 of Article 10, Supplementary Provisions Paragraph 2 and Paragraph 3,
as well as the attached table (newly established), shall come into effect on the date of enforcement of theprovisions listed in Item 2 of Article 1 of the Supplementary Provisions of the Act for Partial Revisionof the Special Measures Act on the Freezing of Assets of International Terrorists in order to Implement
United Nations Security Council Resolution 1267 Concerning the Countering of International Illicit
Financial Movements (Act No. 97 of 2022).
2. Matters concerning verification of identity and retention of records performed before the effectivenessof these amended provisions under the provisions before the amendments shall continue to follow priorpractices.

Attached table (reference to Article 1)

Term

Meaning

Identity Verification A document which is an Identity Verification Document of a Natural Person and toDocumentsofa which a photograph of the natural person is affixed by a Government Authority, andNatural Person With a Passport (meaning a passport listed in Item 5 of Article 2 and a crew member’s
Photopocket-ledger listed in Item 6 of the same article of the Immigration Control andRefugee Recognition Act (Cabinet Order No. 319 of 1951), in which name anddate-of-birth are stated).

Engagement

An engagement agreement (if an engagement agreement is not required, a document

Agreement

relating to the Asset Management Acts or to the preparation for or carrying out of theTransactions.)

Registered Mails

Registered mails, or mails that record acceptance or delivery, or other similar mails.

Mails Not Requiring Mails which may not be forwarded or other similar mails.
Forwarding

Appended Form (reference to Article 11)
Annual Report
To: President of Bar Association
I (the corporation) hereby report such matters that are listed in Paragraph 1, Article 11 of the Rules
Concerning Verification of Client Identity and Retention of Records (hereinafter referred to as the“Rules”) during the reporting period stated below.
Reporting period: From April 1, YYYY until March 31, YYYY
1. Working Conditions as Attorneys
Working conditions as Attorneys (Item 1, Paragraph 1, Article 11 of the Rules) during thereporting period is as follows.
(Please mark  in one of the applicable item)
 (i)I practiced law as Attorneys throughout or part of the period;

 (ii)I performed duties of the organization to which I belong as an in-house Attorneys
throughout the period; or  to Question 3

 (iii) I was absent from practicing law as Attorneys throughout the period due to the following
reasons (as to legal profession corporations, registered foreign legal profession
corporations and attorney at law / registered foreign lawyer joint corporations, meaning
the reasons pertaining to their members).  to Question 6
 a. Advanced age

 b. Childbirth (*)

 c. Childcare (*)

 d. Disease (*)

 e. Injury (*)

 f. Study abroad g. Other reasons (Please mention concretely in the following)* In the case of falling under “b. Childbirth”, “c. Childcare”, “d. Disease” or “e. Injury”, attachmaterials making prima facie showing the reasons.
2. Implementation of Measures for Identity Verification
Implementation of Measures for Identity Verification (Articles 2 through 5 of the Rules) is asfollows (Item 2, Paragraph 1, Article 11 of the Rules).
(1) Implementation of identity verification pursuant to the provisions of Articles 2 through 4 of
the Rules is as follows.

1

Note 1. Identity verification is required not at the time of acceptance, but when Attorneys
conduct Asset Management Acts or prepare for or carry out Transactions. Therefore, if you
conduct Asset Management Acts or prepare for or carry out Transactions during the reporting
period, they must be reported even if you accepted the client's instruction before the reporting
period. Please select answer from (ii) to (iv) below (no multiple answers).
Note 2. Regardless of whether you verify identification only when it is required, or you verify
identification of all clients, if there were no legal matters which required the verification ofclients' identity during the reporting period, mark  in option (i).
Note 3. If you did not consider if the verification is required review and did not verify theclients' identification, mark  in option (iv).
(Please mark  in one of the applicable items)
 (i)There were no legal matters which required the verification of clients' identity; (ii)

There were legal matters which required the verification of clients' identity, and I (we)verified only when verification of client's identity is required; (iii) There were legal matters which required the verification of clients' identity, and I (we)verified identification of all clients regardless of whether it is required; or (iv) I (we) did not verify clients' identification because I (we) did not considered if theverification is required review, or I (we) did not verify clients' identification even though
I (we) considered if the verification is required review and found that there were legal
matters that required the verification.  to Question 3[Examples of legal matters which require the verification of clients' identity]
 Taking custody of assets of 2 million yen or more such as;- A demand for a refund from a money lender of overpayment without going through judicial proceedings, andreceiving the refund at the attorney's deposit account;- A claim for damage resulting from a traffic accident without going through judicial proceedings, and receiving
a payment from an insurance company to the attorney's deposit account; and- Represent an heir with regard to division of inherited property without going through judicial proceedings,
and accept taking custody of compensation to be paid by the client or the other party.
 Preparation for or carrying out of certain transactions (including cases where you are not involved in the transfer
of funds) such as;- A sale of real property in conjunction with division of inherited property;- An M&A; and- An incorporation of a corporation.

(2) I (we) determine the necessity of identity verification and record retention pursuant to theprovisions of Article 2 through 5 of the Rules using the following means.

2(Please mark  in all applicable items)
 (i)I (we) prepare paper medium such as a checklist for identity verification;

 (ii)I (we) introduce a computer system for identity verification; and / or

 (iii) Other means (Please describe below).

(Note: Using the means set forth in (i) or (ii) is not obligatory. When (i) or (ii) is not applicable,
check (iii) and describe the means in sufficient detail.)(3) Implementation of retention of identity verification records and transaction records pursuant
to the provision of Article 5 of the Rules with respect to cases where identity of clients wereverified pursuant to the provisions of Article 2 through 4 of the Rules prior to or during thereporting period is as follows.
Note1. Even if you select (i) for Question “2. (1)”, please select one of the answers from (i) to(iv) on the retention of identity verification records and transaction records if you verifiedclients identity, conducted Asset Management Acts or prepared for or carried out Transactions
prior to the reporting period.
Note 2. If you select (i) for Question “2. (1)” and you have not conducted retention of records
pursuant to Article 5 of the Rules (because there were no legal matters which required
verification of clients identity prior to the reporting period, or because the record retention
period (five years after completion, Article 5 of the Rule) for past legal matters which required
verification of clients identity has passed prior to the reporting period, or because of othercircumstances), please mark  in (iv).
Note 3. If you retain both identity verification record and transaction record pursuant to Article
5 of the Rules, mark  in (i).
(Please mark  in one of the applicable items)□ (i) I (we) retain the identity verification records as well as the transaction records of AssetManagement Acts and Transactions (Paragraph 1 and 2, Article 5 of the Rules); (ii)I (we) retain only the identity verification records (Paragraph 1, Article 5 of the Rules); (iii) I (we) retain only the transaction records of Asset Management Acts and Transactions(Paragraph 2, Article 5 of the Rules); or (iv) I (we) do not retain any records.  to Question 33

(4) I (we) use the following means to retain identity verification records and transaction records
pursuant to the provision of Article 5 of the Rules.
(Please mark  in all applicable items)
 (i)I (we) use model format for client identity verification and record retention prepared by
the Japan Federation of Bar Associations;

 (ii)I (we) introduce a computer system for client identity verification and record retention; and/ or (iii) Others (Please describe below in sufficient detail).

(Note: Using the means set forth in (i) or (ii) is not obligatory. When (i) or (ii) is not applicable,
check (iii) and provide a brief description.)
3. Implementation of proper response when and after accepting instructions for legal matters
I. Proper response when accepting instructions for legal matters
Implementation (Item 3, Paragraph 1, Article 11 of the Rules) of proper response when
accepting instructions for legal matters (Article 6 of the Rules) is as follows.
(1) When I (we) accept instructions for legal matters, as to whether purpose of the instruction forlegal matters relates to a transfer of criminal proceeds or not:
 (i)I (we) review the same; (ii)

There was an instruction or instructions for legal matter, but I (we) did not review thesame; and / or  to Question II

 (iii) There were no instruction for legal matter, so I (we) did not review the same.  to
Question II(Please mark  in one of the applicable item)(2) As a result of the review, there are instructions which were considered to have related to atransfer of criminal proceeds: (i)Yes; or (ii)

No  to Question II(Please mark  in one of the applicable item)4(3) As to the instruction which was considered to have related to a transfer of criminal proceeds,
I (we) responded as follows.
(Please mark  in one of the applicable item) (i)I (we) refused to accept the instruction(s); (ii)I (we) did not refuse to accept the instruction(s); or (iii) I (we) refused to accept some instruction(s) and did not refuse to accept the other
instruction(s).
II. Proper response after accepting legal matters
Implementation (Item 3, Paragraph 1, Article 11 of the Rules) of proper response after accepting
legal matters (Article 7 of the Rules) is as follows.
(1) After accepting instructions for legal matters from clients, there is or are case(s) to which I(we) become aware that the purpose of said instruction relates to a transfer of criminal
proceeds: (i)Yes; or (ii)

No  to Question 4(Please mark  in one of the applicable item)(2) After accepting an instruction to handle legal matters I (we) become aware that the purpose of
the instruction relates to a transfer of criminal proceeds, I (we) responded as follows.
(Please mark  all applicable items)
 (i)I (we) explained it as being illegal and persuaded to abandon pursuit of the purpose,accordingly the client abandoned the pursuit of the purpose;  to Question 4

 (ii)I (we) explained it as being illegal and persuaded to abandon pursuit of the purpose,
however the client did not abandon;  to Question (3) (iii) I (we) explained it as being illegal, however did not persuade to abandon pursuit of the
purpose; and / or  to Question 4
 (iv) I (we) neither explained it as being illegal nor persuaded to abandon pursuit of the
purpose.  to Question 4(Note. If (ii) was marked with , please answer Question (3) below.)(3) After accepting an instruction to handle legal matters I (we) become aware that the purpose of
the instruction relates to a transfer of criminal proceeds, as to the clients who did not abandon
pursuit of the purpose notwithstanding my (our) persuasions, I (we) responded as follows.
(Please mark in one of the applicable item)
 (i)Withdrew from the legal matters;

 (ii)

Did not withdraw from the legal matters;5 (iii) Withdrew from some legal matters and did not withdraw from the other legal matters;or (iv) Others (Please describe below in sufficient detail).

4. Implementation of proper response when taking custody of assets for non-legal matters
Implementation (Item 4, Paragraph 1, Article 11 of the Rules) of proper response (Article 8 of
the Rules) when taking custody of assets including money for non-legal matters during the courseof my practice as Attorneys is as follows.
(1) There are cases where I (we) was requested to take custody of assets including money with norelation to legal matters: (i)Yes; or (ii)

No  to Question 5 (for in-house Attorneys who marked  in (ii) of Question 1, moveto a column of reporting date at the end of the document)(Please mark  in one of the applicable item)(2) When requested to take custody of assets including money, I (we) have examined whether the
purpose of such custody relates to a transfer of criminal proceeds or not: (i)Yes; or (ii)

No  to Question (4)(Please mark  in one of the applicable item)(3) As a result of my (our) examination, I (we) considered that the requests were considered tohave related to a transfer of criminal proceeds: (i)Yes; or (ii)

No(Please mark  in one of the applicable item)(4) There are cases where I (we) was requested to take custody of assets including money which
are not related to legal matters, and I (we): (i)Accepted the requests; ( for in-house Attorneys who marked  in (ii) of 1, move to
Question (8))

 (ii)

Did not accept the requests; or  to Question 5 (for in-house Attorneys who marked in (ii) of 1, move to a column of reporting date at the end of the document) (iii) There are requests which I (we) accepted and did not accept. ( for in-house Attorneys
who marked  in (ii) of 1, move to Question (8))

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(Please mark  in one of the applicable item)(5) When taking custody of assets which are not related to legal matters, I (we) verified the identityof a person who is requesting for the custody of assets:
 (i)

Yes;

 (ii)

No; or  to Question (7) (iii) There are requests to which I (we) verified the identity and did not verify the identity.
(Please mark  in one of the applicable item)(6) As to documents received for verification when having taken custody of assets which are notrelated to legal matters:
 (i)I (we) retain them; (ii)I (we) do not retain them; or (iii) There are requests for which I (we) retain documents and for which I (we) do not retain
documents.
(Please mark  in one of the applicable item)(7) As to documents which describe the relevant assets taken into custody:
 (i)I (we) retain them; (ii)I (we) do not retain them; or (iii) There are requests for which I (we) retain documents and for which I (we) do not retain
documents.
(Please mark  in one of the applicable item)(8) There are cases to which I (we) become aware that the purpose of custody relates to a transfer
of criminal proceeds after having taken custody of assets: (i)Yes; or (ii)

No  to Question 5 (for in-house Attorneys who marked  in (ii) of 1, move to a columnof reporting date at the end of the document)(Please mark  in one of the applicable item)(9) After having known that the purpose of custody relates to a transfer of criminal proceeds, I(we) responded as follows:(Please mark  in all applicable items)
 (i)I (we) explained it as being illegal and persuaded to abandon pursuit of the purpose,accordingly the person who deposited assets including money abandoned the pursuit of
the purpose;7 (ii)I (we) explained it as being illegal and persuaded to abandon pursuit of the purpose,
however the person who deposited assets including money did not abandon;

 (iii) I (we) explained it as being illegal, however did not persuade to abandon pursuit of the
purpose; (iv) I (we) neither explained it as being illegal nor persuaded to abandon pursuit of the
purpose; and / or
 (v)Other responses (Please describe below in sufficient detail).

(for in-house Attorneys who marked  in (ii) of 1, do not answer Questions 5 and 6, andmove to a column of reporting date at the end of the document)
5. Implementation of measures to ensure implementation of preventive measures
Implementation (Item 5, Paragraph 1, Article 11 of the Rules) of measures to ensure Measuresfor Identity Verification (Article 9 of the Rules and Article 10 of the Regulations) is as follows.
I (we) take the following measures to ensure Measures for Identity Verification.
(Please mark  in all applicable items)
 (i)Updating and keeping current the information pertaining to the matters to which identity
is verified; (ii)

Education and training to staff;

 (iii) Preparation of rules concerning implementation of the Measures for Identity Verification;
 (iv)

Appointment of a person who audit and supervise and manage other operations thoseare necessary for adequate implementation of the Measures for Identity Verification;

 (v)Review of Asset Management Acts or Transactions that I (we) conduct, prepares for or
carries out and analyzing the same, and using the results of such investigation andanalysis to change the measures as necessary; (vi) Collection, sorting out and analysis of such information that is necessary to implement
Measures for Identity Verification, taking into consideration National Risk Assessmentof Money Laundering and Terrorist Financing; (vii) Continuous and careful examination of the verification records and transaction records
taking into consideration the result of my (our) review and analysis;
 (viii) When I (we) collect, sorting-out and analyze information pursuant with respect to AssetManagement Acts or preparation for or carrying out of Transactions, preparing for a
document stating the results thereof and keeping them together with verification records
and transaction records; (ix) Conducting an audit necessary for adequate implementation of the Measures for Identity

8Verification; and / or
 (x)I (we) have not taken any of measures listed in (i) through (ix) to a column of reporting date at the end of the document

6. Non-implementation of measures or response listed in Items 2 through 5, Paragraph 1, Article 11of the Rules.
(Please mark )
 I (we) have not implemented any measures or response listed in Items 2 through 5, Paragraph 1,
Article 11 of the Rules because I (we) did not practice as Attorneys throughout the entire period.
Reporting date
Name or attorney

MM

DD

YY
Registration number or
notification number

Name of law office

Address of law office

Note 1.

If you use professional name, please write the professional name.

Note 2.

If you are a legal profession corporation, a registered foreign legal profession corporationor an attorney at law / registered foreign lawyer joint corporation, please write names andaddresses of all offices located in the region of the Bar Association to which this report isto be submitted.

Personal information you have submitted will be strictly managed in accordance with the Federation’s rules
concerning personal information. The Federation may, in some cases, statistically process and analyze personal
information, and publish the result thereof in such manner that an individual may not be identified.

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