Basic Policy for Preventing Money Laundering and Terrorism Financing
The Group positions the prevention of money laundering and terrorism financing (hereinafter, “money laundering, etc.”) as one of the highest priorities in the management of its business and shall adhere to relevant laws and regulations as well as establish effective control environments.
1.Involvement of management
The management understands that money laundering, etc. can be a major operational risk and will become involved in an independent and proactive manner in improving measures to prevent money laundering, etc.
2.Risk-based approaches
Kyushu FG shall take into consideration the results of national risk assessments (National Risk Assessment of Money Laundering and Terrorist Financing) etc. as part of comprehensive and concrete investigations on risks pertaining to its products and services, forms of transactions, regions and countries involved in transactions, and customer attributes. Kyushu FG shall identify and assess potential risks like money laundering, etc., and shall come up with suitable measures to reduce risks.
3.Customer management
The Group shall conduct proper identification at the time of transactions and manage customers in accordance with the customer’s attributes and the transaction at hand. In addition, the Group shall conduct regular surveys and analysis of transaction records and revise its customer management measures accordingly.
4.Economic sanctions and the freezing of assets
Kyushu FG shall take appropriate approaches to dealing with those who are the target of economic sanctions, including the cessation of business relations and the freezing of assets.
5.Notification of suspicious transactions
Kyushu FG shall take appropriate steps to notify the authorities in the event it encounters suspicious transactions in the course of its routine work and monitoring. In addition, if necessary, Kyushu FG shall use the situation surrounding the notification to reinforce its own management stance.
6.Management of correspondent banks
Kyushu FG shall regularly check up on a correspondent bank’s management stance to money laundering, etc. In the event that the correspondent bank turns out to be a shell bank or an institution that is allowed to be used by a shell bank, Kyushu FG shall not enter into or continue contracts with the correspondent bank in question.
7.Implementation of training, etc.
Kyushu FG shall conduct appropriate and ongoing training according to the roles of staff, and maintain and improve its expertise and suitability as an organization as a whole by enhancing its understanding of issues relating to the prevention of money laundering, etc.
8.Inspection of compliance status
Kyushu FG shall regularly inspect its compliance status in the prevention of money laundering, etc., and work to make ongoing improvements based on the results of these inspections.
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