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.

### 16. 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 Verification of Matters for Identification of Clients and Record-Keeping" (hereinafter referred to as the "Rules") with a resolution of the extraordinary general assembly meeting in December 2012. The Federation also established the Regulations on Verification of Matters for Identification of Clients and Record-Keeping (hereinafter referred to as the "Regulations") with a resolution of the board meeting in the same month. The 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 there is suspicion of being used for transfer of criminal proceeds. The Regulations and Rules were put into effect in March 2013. In order to respond to the partial amendment of the Act on Prevention of Transfer of Criminal Proceeds in 2014, the Federation partially revised the Rules through a resolution adopted at an extraordinary general meeting in December 2015, and also partially revised the Regulations through a resolution adopted at the board meeting in January 2016. The Rules and Regulations were put into effect on October 1, 2016, accompanying the full enforcement of the Act partially amended in 2014.

Additionally, the Federation conducted a survey of large-scale law firms with a large number of affiliated members in March 2017 and a survey of all the members of the Federation in July 2017, mainly to ascertain the actual level of compliance with the Rules and Regulations. In addition, the Federation encouraged the members to understand the ML/TF risks, which are likely to arise in connection with the attorney services of each member.

For the purpose of newly establishing (i) provisions requiring members to submit annual reports for ascertaining the level of compliance by members, including verification of identification of clients and retention of records, which are required by the Rules and Regulations and (ii) provisions for stipulating the specific authority to require members to improve their level of compliance after ascertaining the level of compliance, the Rules will be partially revised by a resolution adopted at the extraordinary general meeting of December 2017, and the Regulations will be partially revised by a resolution of the board meeting in the same month. They will be put into force on January 1, 2018.