materials such as guidelines or “model regulations” are provided. 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 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” (hereinafter referred to as the “Guidelines for Supervision”) 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 “JICC”), 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 JlCC'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 JlCC than the prescribed level. In FY2016, with the aim of facilitating the use of this service by minor members, the number of registered credits, one of the requirements for eligibility, was reduced and the coverage was expanded from only obligors to include joint guarantors for loans for corporations.

In FY2016, in response to the full enforcement of the Act on Prevention of Transfer of Criminal Proceeds partially amended in 2014 and the revision of the Guidelines for Supervision, the Association revised the voluntary regulations and published them, thereby promoting the development of necessary systems in the moneylending industry for preventing money laundering and damage inflicted by anti-social forces.

### 10. Fund Transfer Industry

The Japan Payment Service Association is a self-regulatory body whose purpose is to facili-