staff members. In addition, they make and issue posters intended to raise members' and users' awareness about the procedures for verification at the time of transactions.

Moreover, regarding measures to eliminate transactions with anti-social forces, the cooperatives have established internal regulations, including basic policies, based on the government's guidelines and have introduced a clause for Boryokudan exclusion in contract documents. They are also implementing examination as to whether or not customers are anti-social forces based on the database when starting transactions.

## 5 Life Insurance Industry

The Life Insurance Association of Japan (LIAJ), of which all domestic life insurance companies in Japan are members, works to achieve appropriate operations by its members by incorporating AML/CFT and anti-social forces in its Code of Conduct.

LIAJ has compiled the “Countermeasures Against Money Laundering and Terrorist Financing Handbook” and the “Countermeasures Against Money Laundering and Terrorist Financing FAQs” for both executives and regular employees, thereby assisting members in their efforts. In addition, LIAJ also makes posters and presents important points pertaining to the subject on its website.

To address the issue of anti-social forces, LIAJ has issued a directive entitled “Guidelines for Coping with Anti-social Forces in the Life Insurance Industry.” With a view to dissolving insurance contracts of parties found to be anti-social forces or that are engaged with anti-social forces in a manner unacceptable to society, the LIAJ has issued for members entitled “Insurance Contract Rules and Regulations Regarding Anti-social Forces”. In addition, the LIAJ works with the police and other external specialized institutions, creates industry databases on anti-social forces, and takes other necessary steps.

## 6 Non-Life Insurance Industry

As for the non-life insurance industry, with a view to preventing ML/TF, verification of customer identity procedures regarding savings-type insurance or large cash transactions exposed to a high risk of ML/TF have been implemented since 1990. The General Insurance Association of Japan has acted on an industry-wide basis in providing procedures related to customer identification, jointly issuing posters for use in store locations and writing a letter to inform its agencies, which constitute the main channel for the sale of non-life insurance, of the issue.

In addition, in response to the revision of the Act on Prevention of Transfer of Criminal Proceeds in 2011, the Association has compiled and distributed a set of Administrative Reference Materials for the members, in order to facilitate uniform and comprehensive verification of transactions and preparation/preservation of verification records. Moreover, as part of an effort to help customers better understand the CDD process, the Association has set up a special page on its website, targeting general consumers, as well as has issued leaflets to be handed out to customers.

As a measure to address the issue of anti-social forces, the “fundamental policy,” which specifies the industry’s efforts to sever relationships with anti-social forces, and “model arti-