Silviase/jgov_v1.4_full_ann huggingface dataset:
Prefectural Center for Elimination of Boryokudan and the Bar Association established the "Securities Police Liaison Council" in each prefecture, and have improved the effectiveness of the elimination of Boryokudan from the industry and of the prevention of money laundering, through information exchange of the field level and seminars.

Additionally, the Japan Securities Dealers Association established the “Securities Safety Measures Support Center” in March 2009. It is registered as organization for management of information on unjust demands based on the Law Concerning Prevention of Unjust Acts by Boryokudan Members, by the National Public Safety Commission/the National Police Agency. It carries out operations to receive inquiries and consultations from securities companies.

The Japan Securities Dealers Association also established the “Rules regarding Severing Relationships with Anti-social Forces” in May 2010, obligating each member to 1) introduce articles regarding Boryokudan elimination in their transaction clauses etc, 2) screen new and existing customers, and 3) introduce articles regarding assurance by customer, “that he/she is not an anti-social force” when opening a securities account.

## 7 Efforts of Moneylending Industry

Japan’s moneylending industry has a self-regulating body called the “Japan Financial Services Association.” In efforts to prevent damages caused by money laundering and terrorist financing activities and anti-social forces, the Association implements voluntary regulations, which has clarified relevant items for verification purposes to be added to internal regulations by member companies as self-regulation.

In addition, members are provided with reference materials such as guidelines or “model regulations” for use in formulating internal regulations. These guidelines show specific examples of relevant items to be included.

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 the adoption of relevant items was found to be insufficient. As a result, virtually all members (99%) 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, in efforts to facilitate the adoption of said clause.

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

The Association also notes information on preventing damages caused by money laundering, terrorist financing and anti-social forces on the Association’s website in order to familiarize association members with these issues.
## 8 Efforts of Fund Transfer Industry

The Japan Payment Service Association is a fund settlement cooperative whose purpose is to facilitate sound development of advanced payment means issuance services and fund transfer services, as well as to protect users. The Association engages in a variety of countermeasures against money laundering and terrorist financing. In 2010, the Association enacted voluntary regulations pertaining to member systems for accurate response to verification of customer identity and to suspicious transaction reporting for member of fund transfer businesses. 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 fund transfer businesses.

In preparation for the full enforcement of the revised Act on Prevention of Transfer of Criminal Proceeds in April 2013, 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 countermeasures against money laundering and terrorist financing amongst its members through workshops.

## 9 Efforts of Leasing Industry

The Japan Leasing Association is an industry organization comprised of companies engaged in the leasing business. In March 2008, the Association compiled and distributed an educational pamphlet targeting leasing customers regarding the Act on Prevention of Transfer of Criminal Proceeds. In September 2012, 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.

## 10 Efforts of Credit Industry

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 established in December 2009, requiring that its member companies comply.

## 11 Efforts of 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.
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.

Upon the enactment of the revised Act on Prevention of Transfer of Criminal Proceeds, and in light of the 2011 annual Japan Financial Intelligence Center (JAFIC) report published on April 2, 2012, the federation informs its member Associations, and through them individual members, of the objectives of the revised law as well as money laundering crime trends, and also intends to provide relevant information for its members on its website.

## 15 Efforts of Certified Administrative Procedures Specialists

To facilitate implementation of the initiatives of the Act on Prevention of Transfer of Criminal Proceeds, the Japanese Association of Certified Administrative Procedures Specialists 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 member pages in order to familiarize all members with the material.

## 16 Efforts of Certified Public Accountants

The Japanese Institute of Certified Public Accountants disseminates information on countermeasures against money laundering and terrorist financing, not only in regard to the Act on Prevention of Transfer of Criminal Proceeds but also as relates to the Act on Punishment of Organized Crimes, through member newsletters and the association website, in order to thoroughly familiarize members with these issues. In addition, the association conducts member workshops, in which it provides overviews of the Act on Prevention of Transfer of Criminal Proceeds and countermeasures against money laundering.

## Section 2 Efforts for Specified Business Operators and other Parties

### Paragraph 1 [Seminars and Provision of Information] etc. Targeted at Specified Business Operators in 2012

## 1 Explanations in Seminars for Financial Institutions

The NPA jointly held with the Financial Services Agency, seminars on “Suspicious Transaction Reporting” for financial institutions 14 times, at a total of 12 places around the country, from September to November 2012, where they explained case studies of suspicious transaction reporting from the investigative authorities and points which should be kept in mind when filing the reports etc., and provided them with information related to suspicious transaction reporting through answering questions made by employees of
financial institutions and other means.

## 2 Explanation on Workshops for Banking Industry

In June 2012, the Japanese Bankers Association held a seminar in the Tokyo Metropolitan area, where a briefing session on important points was provided by the Financial Services Agency on the subject of the revised Act on Prevention of Transfer of Criminal Proceeds.

Explanation at a Seminar

## 3 Explanation on Workshops for Shinkin Banks (Credit Unions)

In February 2012, the Shinkin Central Bank held a seminar in the Tokyo Metropolitan area, at which time the Financial Services Agency provided an overview and important points on the revised Act on Prevention of Transfer of Criminal Proceeds.

## 4 Formulation/Announcement of "Points to Consider on the Act on Prevention of Transfer of Criminal Proceeds"

The Financial Services Agency formulated and issued a directive entitled “The guideline for implementing the revised Act on Prevention of Transfer of Criminal Proceeds” for financial institutions (October 2012), while the Ministry of Economy, Trade and Industry did the same for financial leasing operators and credit card operators (November 2012), detailing enforcement of the customer verifying obligation and major points regarding the prevention of money laundering and terrorist financing under the Act on Prevention of Transfer of Criminal Proceeds.

In December 2012, the Ministry of Land, Infrastructure, Transport and Tourism formulated and issued its “Overview and Implementation of the revised Act on Prevention of Transfer of Criminal Proceeds: Key Points for Real Estate Agents.”

## 5 Arrangement of Policy on Guidelines by relevant Ministries and Agencies

The Ministry of Economy, Trade and Industry formulated and issued its “Basic Guidelines on the Installment Sales Act (Deferred Payment Sector)” in October 2012. These Guidelines included new inspection items for credit card business operators, i.e. items related to customer identity verification and record preservation and on suspicious transaction reporting, based on the Act on Prevention of Transfer of Criminal Proceeds.

In light of the revised Act on Prevention of Transfer of Criminal Proceeds, the Financial Services Agency partially revised its “The Comprehensive Supervisory Guidelines for Major Banks” and “Financial Inspection Manual” with a view to stepping up measures against crimes related to money laundering, terrorist financing, etc., in November 2012.
## 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.

Website of the National Police Agency

http://www.npa.go.jp

Website of JAFIC

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

## Paragraph 2 Requests Made to Specified Business Operators following the Resolution of the United Nations Security Council

When the United Nations Security Council newly adopts a resolution on measures for freezing the assets related to a person or an organization deemed to be involved in terrorism etc., the National Police Agency, in cooperation with relevant Ministries and Agencies, shall disseminate the content to specified business operators and request the thorough implementation of identification obligation and suspicious transaction reporting obligation on persons or organizations whose assets etc. can be targeted for freezing. And, the targeted persons or organizations of the said measures shall be listed on the website.

## 1 Measures based on the resolutions of the United Nations Security Council

Japan imposes asset freezing measures on parties associated with the Taliban according to the resolutions of the United Nations Security Council. Every time the list of such parties is revised, the National Police Agency requires specified business operators through supervisory authorities to fulfill their obligation of due diligence and ensure the reporting of all suspicious transactions. Such a requirement was made a total of nine times in 2012.

## 2 Measures based on the FATF Public Statement

The Plenary Meeting of the FATF held in February 2012 adopted the Statement which calls on all FATF member countries and regions to apply countermeasures to protect the
international financial system from money laundering and terrorist financing risks emanating from Islamic Republic of Iran and North Korea. In response, the National Police Agency has required through supervisory authorities that specified business operators fulfill their obligation of customer due diligence in accordance with the Act on Prevention of Transfer of Criminal Proceeds, and ensure the reporting of all suspicious transactions.

The FATF Plenary Meetings held in June and October 2012 also adopted a statement concerning the jurisdictions having strategic deficiencies in the measures against money laundering and terrorist financing. The National Police Agency consequently made the same requirement through supervisory authorities.

## Section 3 Progress of the collection of reports and opinion statements in 2012

## 1 Collection of Reports and Opinion Statements by the National Public Safety Commission/the National Police Agency

When suspicion surfaces during the investigation of Furikome fraud or other crimes by the Prefectural Police with regard to the violation of the obligation of customer identity verification and other matters prescribed in the Act on Prevention of Transfer of Criminal Proceeds, the National Public Safety Commission/the National Police Agency (JAFIC) makes requests to the alleged specified business operators for submission of reports or gives directions to the relevant prefectural Police on necessary inquiry.

In 2012, the National Public Safety Commission/the National Police Agency made nine requests to submit report to Postal Receiving Service Providers etc., and gave three directions to Prefectural Police to make necessary inquiry. In addition, based on the result of the past report collection, the National Public Safety Commission/the National Police Agency issued ten opinion statements to competent administrative authorities in charge of supervising specified business operators; specifically, eight statements to the Minister of Economy, Trade and Industry, which is the authority over postal receiving service providers; one to the Minister of Internal Affairs and Communications, which is the authority over telephone receiving service provider; and one to a Prefectural Governor, which is the authority over certified administrative procedures specialists. The purpose of these statements is to encourage these authorities to take necessary measures that will rectify the violations of the Act by their supervising specified business operators. No on-site inspections were performed.
Table 3 Implementation of Request to submit report etc. by the National Public Safety Commission/ the National Police Agency

2008	2009	2010	2011	2012
Number of requests to submit reports to specified business operators	11	16	7	5	9
Number of directions to conduct inquiry to prefectural police	1	2	10	3	3
Number of opinion statements made to competent administrative authorities	4	9	13	10	10

Note: The reports and statements of 2008 are those made after March 1.

## 2 Issuing of Rectification Order by Competent Administrative Authorities Based on Opinion Statements

In 2012, in light of Opinion Statements issued by the National Public Safety Commission/the National Police Agency, the Minister of Economy, Trade and Industry issued eight Rectification Orders to postal receiving service providers, while the Governor of Hiroshima Prefecture issued one Rectification Order to an certified administrative procedures specialist.

This is the first case where the Opinion Statement was released and Rectification Order was issued to the certified administrative procedures specialist since the enforcement of the Act on Prevention of Transfer of Criminal Proceeds.

## Rectification Order against an certified administrative procedures specialist

A male certified administrative procedures specialist undertook a request from a party that had established a fictitious company, which was in fact an attempt to defraud a bank account. When the certified administrative procedures specialist acted as the agent for the offices of the fictitious corporation, he neglected his obligation to verify the identity of the customer as stipulated in the Act on Prevention of Transfer of Criminal Proceeds. This prompted the National Public Safety Commission/the National Police Agency to release an Opinion Statement recommending that the Governor of Hiroshima Prefecture, who is the competent administrative authority overseeing certified administrative procedures specialist in its jurisdiction, issued a Rectification Order demanding proper observation of the Act.

## 3 Arrests in Violation of Rectification Orders

A postal receiving service provider who had violated the Rectification Orders issued by the Minister of Economy, Trade and Industry was arrested in violation of the Act on Prevention of Transfer of Criminal Proceeds (Rectification Order violation).

This arrest on Rectification Order violation was the first of such arrest since the enforcement of the Act on Prevention of Transfer of Criminal Proceeds.
## Arrest of Postal Receiving Service Provider on Violation of Rectification Order

A male postal receiving service provider neglected his obligation to verify the identity of a customer as stipulated in the Act on Prevention of Transfer of Criminal Proceeds. This prompted the National Public Safety Commission/the National Police Agency to release an Opinion Statement recommending that the Minister of Economy, Trade and Industry, which is the competent administrative authority overseeing postal receiving service providers, to issue a Rectification Order demanding proper observation of the Act. The individual was arrested after ignoring the Rectification Order to appropriately enforce proper customer identity verification in violation of the Act on Prevention of Transfer of Criminal Proceeds. (Tokyo Metropolitan Police Department)
# Reports of Suspicious Transactions

The Act on Prevention of Transfer of Criminal Proceeds requires specified business operators to file a report to a competent administrative authority if a transaction is suspected to be related to criminal proceeds. This measure was made obligatory for the first time in the Anti-Drug Special Provisions Law and was taken over to the Act on Prevention of Transfer of Criminal Proceeds through the Act on Punishment of Organized Crimes.

## Section 1 System Outline

## 1 Purpose

The Suspicious Transaction Reporting System aims to support investigation on money laundering and its predicate offences as well as terrorist financing, to prevent criminals' illegal use of the services of specified business operators and to ensure soundness and trust of business activity.

## 2 Flow of Suspicious Transaction Reporting

Information reported by specified business operators is collected at the National Public Safety Commission/the National Police Agency (JAFIC) via the competent administrative authorities. JAFIC arranges and analyzes suspicious transaction reports (STRs), check the importance of them, and then disseminates the useful information to investigative authorities such as the Prefectural Police, the Public Prosecutors Office etc.

The investigative authorities receive and use STRs as clues for criminal investigation, and for countermeasures against organized crime such as the detection of criminal proceeds and the tracing of the source of illicit funds. JAFIC also provides foreign FIUs with information of overseas transactions if needed, in order for them to trace criminal proceeds transferred across international borders etc.

Furthermore at JAFIC, a detailed analysis of STRs is carried out by using the information accumulated by the police, and the results of analysis are disseminated to related investigative authorities.
Figure 4-1 Flow of STRs from Specified Business Operators, through JAFIC to Investigative Authorities

## 3 Cases in which Reporting is Required

Under Article 8 (pre-revision Article 9) of the Act on Prevention of Transfer of Criminal Proceeds, considering factors such as findings made in the verification process, specified business operators (excluding professions such as lawyers and certified accountants) are required to promptly file an STR to the competent administrative authority when they suspect, during the course of their businesses, that assets they received are criminal proceeds or that their client commits an offence of concealment of criminal proceeds (i.e. violations of Article 10 of the Act on Punishment of Organized Crimes or Article 6 of the Anti-Drug Special Provisions Law).

Figure 4-2 Cases where STRs are required