by indicating in pamphlets for members the overview of the Act on Prevention of Transfer of Criminal Proceeds and specified business operators' obligations.

## 15 Bar Associations

The Japan Federation of Bar Associations had been examining the relation between anti-money laundering measures and the duties of a lawyer, recognizing the importance of the measures. Following the amendment of the Act on Prevention of Transfer of Criminal Proceeds in 2011, the Federation fully revised the "Rules on Identification of Clients and Record-Keeping" and established the "Rules on Confirmation of Matters for Identification of Clients and Record-Keeping" (hereinafter referred to as the "New Rules") with a resolution of the extraordinary general assembly meeting in December 2012. The Federation also established the Regulations on Confirmation of Matters for Identification of Clients and Record-Keeping (hereinafter referred to as the "New Regulations") with a resolution of the board meeting in the same month. The New Regulations and Rules stipulate the obligations of a lawyer; e.g., verifying the identity of a client, preserving the records for certain practices, and not accepting a request if suspected to be used for transfer of criminal proceeds. The rule was put into effect in March 2013.

The Federation distributed to bar associations and federations of bar associations instruction manuals concerning the New Rules and Regulations and a model format for record-keeping in order to raise members' awareness about these matters. It also posted them on its members-only website so that members can view them anytime. The Federation also exchanges opinions with major law firms about AML/CFT measures and holds seminars for special foreign members, members and secretariat staff of law firms. When accepting requests for legal service, lawyers must carefully consider whether or not the purposes of the requests are related to the transfer of criminal proceeds in light of the clients' attributes, their business relationship with the clients and the contents of the requests. Therefore, as a guideline for the consideration, the "Risk Based Approach Guidance for Legal Professionals" (published in October 2008) and "Money Laundering and Terrorist Financing Vulnerabilities of Legal Professionals" (published in June 2013), which were formulated and published by the FATF, were translated and used as reference materials in the seminars.

In addition, the Federation formulates and provides e-learning programs concerning the New Rules and Regulations to members as part of training activity and provides educational materials, including training videos and FAQ, to bar associations across the country.

Bar associations hold seminars using the above educational materials on the occasion of twice-yearly training sessions for new lawyers and ethics training sessions in order to raise their awareness about the New Rules and Regulations.

## 16 Judicial Scriveners' Associations

Upon extensive consideration of the relation between money laundering countermeasures and the work of judicial scriveners, the Japan Federation of Shiho-Shoshi Lawyer's Associations partially revised its "Federation Customer Verification and Record Preservation Criteria" in October 2007. Furthermore, on February 15th, 2008, a resolution was adopted by the