Silviase/jgov_v1.4_full_ann huggingface dataset:
tions and judicial scriveners, etc.

Payment of utility fees is specified by ordinance of the competent ministries as transactions for which simplified customer due diligence is permitted in light of the risk level of transfer of criminal proceeds through the said transaction indicated in NRA, so it should be excluded from the scope of specified transactions conducted by financial institutions and judicial scriveners, etc.

Meanwhile, transactions that are recognized as suspected money laundering and transactions that are conducted in a manner markedly different from the same type of transaction are specified by ordinance of the competent ministries as transactions requiring special attention in customer due diligence, so they should be added to the scope of specified transactions conducted by financial institutions and judicial scriveners, etc.

In addition, when a specified business operator conducts two or more transactions with the same customer at the same time or in succession and when it is obvious at first glance that the said two or more transactions represent a single transaction divided in order to reduce the transaction value per transaction, they should be regarded as a single transaction.

B. Formulation of rules concerning transactions for which strict due diligence is highly necessary

Specified transactions with foreign PEPs (Politically Exposed Persons, such as heads of state, other persons specified by ordinance of the competent ministries, former PEPs, their families, and customers whose beneficiary owners meet any of these descriptions; the same shall apply hereinafter) should be added to the scope of transactions subject to strict verification at the time of transactions.

C. Formulation of rules concerning transactions with customers for whom verification at the time of transactions has already been implemented

Transactions recognized as suspected money laundering and other transactions specified by ordinance of the competent ministries as transactions requiring special attention in customer due diligence (e.g., transactions conducted in a manner markedly different from the same type of transaction) should not be exempted from the application of the rule that obligates verification at the time of transactions even if they are transactions with customers for whom verification at the time of transactions has already been implemented.

(3) Overview of the amendment of the Ordinance for Enforcement of the Act on Prevention of Transfer of Criminal Proceeds, etc.

A. Amendment associated with the enforcement of the amended act

(a) Method of making judgment regarding reporting of suspicious transactions

Comparison with the manner of ordinary transactions, comparison with transactions conducted with the relevant customer in the past, and consistency with verification at the time of transactions are specified as items prescribed by the competent ministries. Verifying whether or not there are suspicious points concerning the relevant transaction in accordance with the items prescribed by the competent ministries is specified as a method prescribed by the competent ministries.
(b) Appropriate measures for verification at the time of transactions

Risk assessment by specified business operators, ongoing scrutiny of preserved verification and transaction records and collection of necessary information are specified as measures that should be commonly implemented by specified business operators when implementing customer due diligence measures in order to appropriately conduct verification at the time of transactions.

B. Amendment associated with the enforcement of the amended order

(a) Transactions requiring special attention in customer due diligence

The following transactions are specified as transactions requiring special attention in customer due diligence:

*Suspicious transactions

*Transactions conducted in a manner markedly different from the same type of transaction.

(b) Persons who occupy important positions in foreign governments, etc.

Regarding transactions with persons who occupy important positions in foreign governments, etc., the following matters should be recorded as verification records:

*Scope of foreign PEPs

*In the case of customers who are PEPs, the fact that they are PEPs and the reason for recognizing them as PEPs

C. Amendment intended to respond to the FATF recommendations

(a) Method of customer identification concerning customer identification documents without a photo

When customer identification documents without a photo, such as health insurance certificates and pension books, are used, additional necessary identification measures, such as sending documents related to the transaction to the residence of the customer by registered mail as postal item requiring no forwarding, etc., should be implemented, in addition to the presentation of the said documents.

(b) Identification of beneficial owners

Regarding “beneficial owners” of corporations, identification should be implemented in order to track down the natural persons who control the corporations through voting rights or other means.

(c) Method of verifying the proxy of persons in charge of transactions

Verifying the possession of an employee identification card should be deleted from the scope of methods of verifying the possession of legitimate authority to conduct transactions by a corporation’s person in charge of transactions, and the registry of a person as an executive should be limited where the said person is registered as an officer with representative authority of the corporation.

D. Other points of the amendment

(a) Addition of individual number cards to the scope of customer identification documents

Following the enforcement of the Act on the Use, etc. of Numbers to Identify Specific Individuals under Administrative Procedures (Act No. 27 of 2013), the individual
number card should be specified as an identification document.

Documents designated by the National Public Safety Commission should be excluded from the scope of customer identification documents and supplementary documents and the notification card specified by the same act should be designated under a public notice as documents that should be excluded from the scope of customer identification documents.

(b) Review of the method of verifying customer identification data associated with the amendment of the Act on Electronic Signature Authentication Services by the Japan Agency for Local Authority Information Systems

Following the amendment of the Act on Electronic Signature Authentication Services by the Japan Agency for Local Authority Information Systems (Act No. 153 of 2002), the method of verifying customer identification data based on the provision of the same act should be reviewed.

(c) Simplification of verification at the time of transactions in the case of cash payment of utility fees

Some of the transactions related to the payment of utility fees, school enrollment fees, etc. whose risk of being used for ML/TF is deemed to be very low should be added to the scope of transactions for which simplified customer due diligence is permitted.

## 3 Other points of the amendment

As a result of the revision of the organization of the Ministry of Agriculture, Forestry and Fisheries under the Cabinet Order for Partial Amendment of the Ordinance on the Organization of the Ministry of Agriculture, Forestry and Fisheries, the inspection authority entrusted by the Minister of Agriculture, Forestry and Fisheries to the Directors-General of Regional Agricultural Administration Offices has been integrated into the authority of the Minister. Therefore, under the Order for Enforcement of the Act on Prevention of Transfer of Criminal Proceeds, an amendment was made to the provision for the entrustment of the Minister of Agriculture, Forestry and Fisheries' inspection authority concerning agricultural cooperatives to Directors-General of Regional Agricultural Administration Offices.
## Chapter 3

## Efforts of Specified Business Operators and Administrative Authorities to Promote Countermeasures against Money Laundering and Terrorist Financing

In order to effectively implement countermeasures against money laundering, it is critical that every obligation imposed on specified business operators is properly enforced. For this purpose, robust efforts have to be made at the private sector level. JAFIC is working together with relevant competent ministries on providing various outreach programs to support their own efforts by organizing an AML/CFT workshop and posting the latest information on the website.

Importantly, JAFIC would, when there is non-compliance, exercise its supervisory power over the non-compliance in consultation with the supervising administrative authority to issue a rectification order against the specified business operators (except for lawyers) concerned.

## Section 1 Efforts of Specified Business Operators

## 1 Banking Industry

The “Japanese Bankers Association” (hereinafter referred to as “JBA”), of which most of the banks operating in Japan are members, established the “Working Committee on Money Laundering Issues” within the JBA in 1990 and, since then, has been taking AML/CFT measures, such as preparing and providing notices on items to keep in mind regarding CDD and STR filing, preparing and distributing seminar handbooks to members, giving seminars for its members, and so on. Furthermore, the JBA prepares leaflets, posters or the like to inform customers of CDD procedure. In addition, the JBA is promoting organizational measures on issues related to ML/TF inside or outside of Japan by following, at all times, the development of AML/CFT measures at the FATF, exchanging and sharing information constantly with foreign bankers associations or the like, making responses to the FATF’s mutual evaluations of Japan, and so forth. The JBA has been playing a leading part in the efforts of the banking industry, with “Code of Conduct,” (revised in November, 2013) which provides matters on compliance with laws or regulations including the prevention of ML/TF and confrontation with anti-social forces, and has prompted its members to put such into practice.

## 2 Shinkin Banks (Credit Unions)

As for the credit union industry, in 1997 the National Association of Shinkin Banks established the Shinkin Banks Ethics Program (re-named the Shinkin Banks Action Program in 2005), under which it is aiming for “strict observance with laws, regulations and rules” and
these activities, the Association promotes the development of systems related to the pre\-vention of damage inflicted by anti-social forces in the moneylending industry.

## 9 Fund Transfer Industry

The Japan Payment Service Association is a self-regulatory body whose purpose is to facilitate sound development of advanced payment means issuance services and fund transfer services, as well as to protect users' profits. The Association engages in a variety of AML/CFT. In 2010, the Association enacted voluntary regulations pertaining to members' internal systems for ensuring of verification of customer identity and suspicious transaction reporting for members. In March 2011, the Association devised an internal regulation model, as well as a system to disseminate information on parties subject to asset freezing provided by the Financial Services Agency, also for members.

In response to the partial revision of the Act on Prevention of Transfer of Criminal Proceeds in 2014, the Association provides advance announcements to members on information regarding the revised act, as well as providing this information on its website. The Association also takes up the issue of AML/CFT amongst its members through workshops.

## 10 Leasing Industry

The Japan Leasing Association is an industry organization for the public interest, comprised of companies engaged in the leasing business. In March 2008, the Association compiled and distributed an educational pamphlet regarding the Act on Prevention of Transfer of Criminal Proceeds for leasing customers. In September 2012, following the revision of the Act on Prevention of Transfer of Criminal Proceeds (2011), the Association compiled and distributed a pamphlet regarding the revised Act, which was also posted on its website along with related materials, in efforts to further familiarize association members with the issues.

In addition, the Japan Leasing Association holds an annual training program (advanced course), in which trainees, primarily leasing company managers, are trained in the Act on Prevention of the Transfer of Criminal Proceeds.

## 11 Credit Industry

In November 2012, the Japan Consumer Credit Association has incorporated items on verification of customer identity and on suspicious reports based on the Act on Prevention of Transfer of Criminal Proceeds into its comprehensive credit purchase regulations, requiring its member companies to comply with them.

In addition, as part of its effort to promote the severance of relations with anti-social forces, the Association also collects information concerning anti-social forces from the National Center for Removal of Criminal Organizations and has developed a database for industry-wide sharing for members to make inquiries as to whether a certain person is an anti-social force. The operation of the inquiries system started in April 2014.

## 12 Real Estate Industry

In December 2007, the real estate industry established the "Liaison Council for Preventing
Transfer of Criminal Proceeds and Preventing Damage by Anti-social Forces in the Real Estate Industry" so that the real estate industry as a whole, can promote collective efforts to prevent the transfer of criminal proceeds and eliminate anti-social forces. It proceeds with taking measures to share the information regarding the operation of systems including the Act on Prevention of Transfer of Criminal Proceeds, through efforts such as agreeing to the development of a responsibility system within relevant business operators, and preparing and distributing brochures etc. for the purpose of enlightenment.

Following the enforcement of the revised Act on Prevention of Transfer of Criminal Proceeds in 2011, the Council has updated its handbook for real estate agents and enhanced its FAQ section concerning the outline and implementation of the revised Act.

In addition, the Council invited lawyers and other experts as lecturers at workshops for members to provide explanations about actions to be taken in response to the amendment of the Act on Prevention of Transfer of Criminal Proceeds.

## 13 Jewelers and Precious Metals Industry

Japan Jewellery Association, which is comprised of jewelers, etc., is raising members' awareness about the Act on Prevention of Transfer of Criminal Proceeds and issuing alerts. For example, it is posting information related to the Act on Prevention of Transfer of Criminal Proceeds on its website in order to deepen understanding of the legal system.

Meanwhile, the Japan Re-Jewelry Council, which is holding workshops for jewelers in order to foster personnel who will support the secondary jewelry market, requires persons aiming to acquire the qualification of “remodel counselor,” who have advanced capability to provide products which meet customers’ requests, to acquire knowledge concerning the Act on Prevention of Transfer of Criminal Proceeds.

The Japan Gold Metal Association, which is comprised of gold bullion dealers, is raising members' awareness about the Act on Prevention of Transfer of Criminal Proceeds and issuing alerts in order to deepen their understanding of the legal system.

## 14 Secondhand Goods Dealers and Pawnbrokers

The Federation of Secondhand Goods Dealers Crime Prevention Cooperation Associations in Tokyo, which is the largest group of secondhand goods dealers related to crime prevention in Japan, is raising members' awareness about AML/CFT by indicating in its handbook for members the obligations imposed at the time of precious metal transactions under the Act on Prevention of Transfer of Criminal Proceeds.

The Japan Ticket Association is comprised of licensed secondhand goods dealers who also engage in ticket sales. The Association has compiled a manual of obligations required by the Act on Prevention of Transfer of Criminal Proceeds related to precious metal transactions. This manual is intended to help familiarize members with AML/CFT.

The Tokyo Pawn-Shop Cooperative is raising members' awareness about matters on the overview of the Act on Prevention of Transfer of Criminal Proceeds and specified business operators' obligations described in pamphlets for members.
Preventing the Transfer of Criminal Proceeds," instructing scrivener associations to inform their members on the subject. The purpose of these efforts is to establish a working policy where scriveners take steps to avoid taking on any responsibility in cases in which there is a risk that their services might be misused for money laundering.

In addition, the Japan Federation of Shio-Shoshi Lawyer's Associations, the Block Judicial Scrivener Associations, and other Judicial Scrivener Associations hold training sessions on the subject for both members and new employees. Since judicial scriveners must verify the personal identity of clients as part of their job duties, this training teaches them how to verify customer identity records and keep transaction records based on the Act on Prevention of the Transfer of Criminal Proceeds.

Since 2014, the Federation has been holding workshops for judicial scriveners with respect to the Act on Prevention of Transfer of Criminal Proceeds and AML/CFT, with personnel of the National Police Agency serving as lecturers.

## 17 Association of Certified Administrative Procedures Specialists

To facilitate implementation of the initiatives of the Act on Prevention of Transfer of Criminal Proceeds, the Japan Federation of Certified Administrative Procedures Specialists Associations has compiled a handbook entitled "Handbook on Customer Identity Verification under the Act on Prevention of Transfer of Criminal Proceeds," which has been distributed to all members. In addition, the Association presents information on the Act to its members through its website in order to familiarize all members with the material.

In January 2014, the Association also partially revised the “Ethics of Certified Administrative Procedures Specialists,” which specifies the basic approach to the performance of the duties of certified administrative procedures specialists and introduced a provision concerning the verification of the client identification items.

As well, the Association and prefectural associations of certified administrative procedures specialists are raising awareness about the verification of the customer's identification items and preservation of records on such verifications and transactions, as well as about the development of account books related to business operations specified by the Administrative Scrivener Act, via workshops for new members and compliance workshops, in light of the Act on Prevention of Transfer of Criminal Proceeds.

## 18 Japanese Institute Certified Public Accountants

The Japanese Institute of Certified Public Accountants disseminates information on AML/CFT in regard to the Act on Prevention of Transfer of Criminal Proceeds through member newsletters and the association website, in order to thoroughly familiarize members with these issues. The Institute also periodically conducts a survey on members in order to grasp the status of members' operations and compliance with obligations such as verification of identification items.

In addition, the association conducts member workshops, in which it provides overviews of the Act on Prevention of Transfer of Criminal Proceeds and AML/CFT.
## Section 2 Collaboration with the private sector

## Paragraph 1 AML/CFT Workshop for Information sharing and feedback in 2015

## 1 Workshops for Financial Institutions

The National Police Agency jointly held with the Financial Services Agency, the “Suspicious Transaction Reporting Workshop” for financial institutions 14 times, at a total of 12 places around the country, from October to November 2015, where they gave feedback learned from case studies of actual investigations involving STR information and advice with regard to key points in performing the reporting work and explained the overview of the amendment of the Act on Prevention of Transfer of Criminal Proceeds in 2014.

In addition, personnel of the Financial Services Agency were sent to briefing sessions held in Tokyo by the Shinkin Central Bank in February in 2015, by the Japan Payment Service Association in November and by the JBA in December in order to explain the overview of the amendment of the Act on Prevention of Transfer of Criminal Proceeds in 2014.

Moreover, personnel of the National Police Agency visited 87 banks and other financial institutions across Japan and provided explanations regarding example cases of suspicious transaction reporting and points of attention concerning reporting work.

## 2 Briefing Sessions for Real Estate Agents

In December 2015, the National Police Agency sent personnel to briefing sessions for real estate agents held in four places across the nation by the Ministry of Land, Infrastructure, Transport and Tourism to provide explanations concerning the overview, etc. of the amendment of the Act on Prevention of Transfer of Criminal Proceeds in 2014.

## 3 Sending Notification to Postal Receiving Service Providers

In March 2015, the Ministry of Economy, Trade and Industry sent a notification to postal receiving service providers of the overview of the amendment of the Act on Prevention of Transfer of Criminal Proceeds in 2014 and points of attention concerning verification at the time of transactions in order to raise awareness about information that they need to acquire as postal receiving service providers.

## 4 Sending Notification to Telephone Forwarding Service Providers

In August 2015, the Ministry of Internal Affairs and Communications sent to telephone forwarding service providers a notification of the overview of the amendment of the Act on Prevention of Transfer of Criminal Proceeds in 2014 and verification items at the time of transactions in order to raise awareness about information that they need to acquire as telecommunications business operators.
## 5 Seminars for Judicial Scriveners

The National Police Agency dispatched its officers to seminars for judicial scriveners, which were held by the Japan Federation of Shio-Shoshi Lawyer’s Associations in Hiroshima in December 2015, and provided explanations on the outline of the amendment of the Act on Prevention of Transfer of Criminal Proceeds in 2014.

## 6 Publication of List of Reference Cases of Suspicious Transactions

Competent administrative authorities published the “List of Reference Cases of Suspicious Transactions,” which indicates red flags to which the business operators should pay particular attention to find any suspicious activities behind them when performing the reporting obligation.

## 7 PR on Website

The website of JAFIC has been created within the National Police Agency website, and its annual reports, the current status of JAFIC's activities, and a description of the Act on Prevention of Transfer of Criminal Proceeds are made available for public viewing.

Top page of the website of the National Police Agency

http://www.npa.go.jp

Top page of the website of JAFIC

http://www.npa.go.jp/sosikihanzai/jafic/index.htm

JAFIC Annual Report