Basic Policies for Anti-Money Laundering and Combating the Financing of Terrorism
The Iyogin group (hereinafter “the Group”) 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 Group as a financial groupwith 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 Response(1) The Board of Directors recognizes and understands the importance of countermeasures toprevent Money Laundering, etc., and shall take the initiative in focusing on suchcountermeasures.
(2) The Group shall determine persons responsible for countermeasures to prevent Money
Laundering, etc., and a department for the oversight thereof, thus establishing centralized
management systems, and the Group as a whole shall tackle Money Laundering, etc., in across-organizational manner, based on cooperation between related departments.
2. Risk Management(1) The Group shall execute appropriate risk management based on a risk-based approach,including by effectively utilizing IT systems and various types of data to identify and evaluate
risks related to Money Laundering, etc. and implement risk mitigation measures for each type ofrisk.
(2) In bank transactions, the Group shall establish systems for preventing Money Laundering, etc.,
by implementing appropriate confirmation measures, etc., for foreign remittances ordered andreceived, export and import transactions, ship financing, and other types of transaction withoverseas. The Group shall also implement appropriate transaction monitoring and screening, andestablish systems for accurately detecting, monitoring, and analyzing suspicious customers andtransactions.
3. Compliance with Laws and Regulations, etc., and Appropriate Customer Due Diligence
Measures
The Group shall comply with various laws and regulations, etc., related to the prevention ofMoney 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 Group shall report suspicious transactions andappropriately implement measures against persons whose assets have been frozen, etc.
5. Correspondent Bank Management
In bank transactions, the Group shall conduct regular investigations of correspondent banks, inorder to verify and monitor their systems for preventing Money Laundering, etc. In addition, theGroup shall not enter into or maintain correspondent banking arrangements if a correspondentbank is a shell bank, or permits transactions with shell banks.
6. Conducting Training, etc.
The Group shall conduct necessary and appropriate training, etc., for all officers and employees,
in accordance with their roles, on an ongoing basis, and the Group as a whole shall take steps toenhance understanding of countermeasures to prevent Money Laundering, etc., and maintain andenhance expertise and qualifications.
7. Anti-bribery and Anti-corruption
The Group 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 and Improvement of Effectiveness, etc.
The Group shall regularly evaluate the effectiveness and validity of all initiatives related to theprevention of Money Laundering, etc., and take steps to strengthen the system by making
improvements as necessary, including a review of management systems.