customers, and 4) ban the conclusion of contracts with anti-social forces. Following the amendment of the Act on Prevention of Transfer of Criminal Proceeds in 2011, the "FAQ concerning the Act on Prevention of Transfer of Criminal Proceeds and Related Cabinet Orders and Ministerial Ordinances" was revised in August 2012, and "Members' Concept of Reporting Suspicious Transactions" was revised in March 2013 so as to raise members' awareness about actions to be taken based on the amendment of the same act.

## 8 Moneylending Industry

Japan’s moneylending industry has a self-regulating body called the “Japan Financial Services Association.” In efforts to prevent ML/TF and damages caused by anti-social forces, the Association implements voluntary regulations providing that relevant items should be added to internal regulations which refer to the key to internal control by members. In addition, members are provided with reference materials such as guidelines or “model regulations.” These guidelines show specific examples of relevant items to be included. Moreover, to ensure effective voluntary regulation, members were inspected on the full body of their internal regulations in FY2011, and guidance and instruction were provided where any deficiency was found. As a result, all members have now devised compliant regulations.

In September FY2011, a Boryokudan exclusion clause was added to contract formats sold to members, and the revised format was posted on the Association's website, enabling not only members but all moneylending businesses to view these materials, and encouraging to adopt said clause in moneylending business. In addition, the Association also notes information on preventing ML/TF and damage caused by anti-social forces on the Association's website in order to familiarize association members with these issues.

The Association conducts inspections on both document-based and onsite-based. The Association audits member company compliance by assessing how well internal systems are established based on the directive entitled “Preventing Damages Caused by Money Laundering, Terrorist Financing, and Anti-social Forces” provided in the internal regulations.

In FY2014, in light of the revision of the Financial Services Agency’s “Comprehensive Guidelines for Supervision of Money Lenders,” the Association also made necessary revisions to voluntary regulatory rules, etc. and it inspected members with respect to all of their internal regulations and provided individual instructions as necessary. It also collects information from the National Center for the Elimination of Boryokudan and commissioned Japan Credit Information Reference Center Corp. (hereinafter referred to as “JlCC”), which is a designated credit information organization under the Money Lending Act, to start specified information inquiry service, which makes it possible for members to make inquiries about whether a certain person is an anti-social force.

In FY2015, in order to contribute to the promotion of inquiries as to whether a certain person is an anti-social force in terms of ex-post verification, the Association started an additional service, i.e. a specified information feedback service, which matches registered credit information with JICC's information concerning anti-social forces at a prescribed interval and reports the results to user members, in response to requests from members who have registered a larger volume of credit information with JICC than the prescribed level. Through