AML/CFT Global Policy

Recognizing the importance of anti-money laundering and combating the financing of terrorism (hereinafter referred to as "AML/CFT"), the JACCS Group has established the following policy regarding AML/CFT.

The JACCS Group shall work toward AML/CFT as a whole, and shall construct a consistent system while giving due consideration to the differences in geographic and political environments in the countries and regions to which each group of companies belongs.
The JACCS Group shall determine the group-wide policies, procedures, plans, etc. for AML/CFT including this policy, and verify whether they are implemented in a consistent manner.
In addition, we will establish a system for sharing information within the Group that is needed for group-wide risk assessment and ensuring the effectiveness of AML/CFT, such as the status of risk assessment and risk reduction measures implemented by each group company, and reporting procedures for major events related to money laundering and terrorist financing (hereinafter referred to as "ML/TF")
Each Group company understands that ML/TF risks can be significant management risks, and establishes an organizational structure for AML/CFT with the leadership of each company's management team.
In establishing an organization system, appropriate positions of personnel are to be allocated in accordance with the principle of "The three lines of defense" and so that departments can play their roles.

Based on the concept of a risk-based approach, the JACCS Group will visualize the risks of the Group as a whole through the identification and assessment of the risks of its own ML/TF, and implement reduction measures commensurate with the risks of each Group company in order to contribute to the reduction of the risks of the Group as a whole.
In order to implement risk reduction measures including the procedures set forth in Article 3 through 7 in a consistent manner as a whole group, a system which is capable of smoothly implementing necessary information sharing, integrated management, etc. is to be established. In such case, the following care shall be taken:

1. 1.
   Pursuant to the contents of the businesses of each group, the status of occurrence of cases concerning ML/TF risk assessment and ML/TF implemented by the governments of the countries and regions to which each group belongs, and the results of mutual examination by FATF(Financial Action Task Force), etc.
2. 2.
   Coordination with group companies shall be facilitated so that a system can be constructed based on understanding of the Information Protection Legislation, the stands of regulatory authorities, etc. applicable to each group company, such as the Personal Information Protection
3. 3.
   If the laws and regulations, etc. concerning the AML/CFT of the national and regional groups to which each group belongs are not stricter than Japan, the provision of information, instructions and support, etc. required to ensure that the group company can respond consistently with the policy, procedures, plan, etc. of the group as a whole.
   The group companies will observe the laws, regulations, guidelines and other regulations concerning the AML/CFT in the country and region to which each group belongs, and at the same time, establish and implement the risk reduction measures, including the procedures mentioned in Article 3 through 7 based on the results of the risk assessment for each group

In addition to investigating and confirming the customer information and the transaction content etc. performed by the relevant customer, the JACCS Group shall conduct a continuous customer management (Customer Due Diligence) in accordance with the risk evaluation of all customers after conducting a risk evaluation.
Each group company shall, after providing for "Policies on the acceptance of customers," establish procedures for the confirmation (Know Your Customer) of information on customers and the customer management, and apply and implement these procedures in an appropriate

JACCS group are to analyze the status of transactions with customers, detect abnormal transactions, etc., and make notification, etc. to the authorities, while, in the case of detecting a transaction suspected to be sanctioned, precisely implement the filtering of transactions. Each group company shall establish an appropriate system for transaction monitoring and filtering to enable the detection to be responded to risks with regard to the transactions which result in a notification of Suspicious transactions(refer to the following Article 5) and transactions subject to sanction, etc.

In cases of detecting uncertain transactions that are suspected of being ML/TF (hereinafter referred to as "Suspicious transactions"), the JACCS Group shall immediately file reports to the authorities, etc. in order to fulfill obligations under laws and regulations, examine the effectiveness of the risk reduction measures with regard to the transactions for which it has made a notification, and review the risk reduction measures as necessary.
In order to properly implement the notification of "Suspicious transactions," each group company shall establish a system for accurately detecting, monitoring, and analyzing suspicious customers and transactions, and shall develop procedures for implementing such a notification,

The JACCS Group will endeavor to secure and train officials required for AML/CFT.
The companies of each group shall establish educational programs concerning the state of AML/CFT, conduct training and other activities related to AML/CFT on an ongoing basis, and nurture the awareness of the importance of AML/CFT and other factors.

The JACCS group shall periodically verify the compliance with each procedure and the effectiveness of AML/CFT situation, and review it as required.
Each Group company shall, in addition to the internal control divisions and other divisions conducting verification and improvement as appropriate, conduct periodic audits by independent internal audit divisions and strive to further improve the system based on the results of these