The Yamaguchi Financial Group, Inc. and our group companies ("YMFG") recognizes the importance of anti-money laundering and counter terrorist financing (AML/CFT). YMFG will work on AML/CFT continuously based on the following policy.

Operation Policy

• YMFG shall comply with laws and regulations relating to AML/CFT.

Organizational Structure

• The YMFG's Board of Directors shall establish money laundering prevention systems as the top management issue.
• YMFG shall develop a unitary internal control system to ensure the effectiveness and efficiency of AML/CFT.

Time of Transaction

• YMFG shall develop internal control system in order to carry out necessary and timely measures in an appropriate manner on transaction confirmation.

Customer Management Measures

• YMFG shall continue to improve its money laundering prevention system, reviewing risk mitigation measures, analyzing and conducting appropriate customer due diligence processes based on a risk-based approach.

Sanctions and Freezing Asset

• YMFG shall comply with relevant provisions etc., promogulated by YMFG, pursuant to the applicable laws, rules and regulations concerning sanctions.
• YMFG shall take asset-freezing measures in respect of entities and individuals, pursuant to applicable laws, rules and regulations concerning asset freezing.

Anti-Bribery & Prevention of Corruption

• YMFG shall consistently refuse any demand for a bribe and offer no gifts and entertainment, charitable, philanthropic and political donations that exceed social norms.
• YMFG shall not use our statuses or positions in the companies to seek personal interests from customers as well as business partners.
• YMFG shall not engage in or be involved in any form of corruption.

Management of Correspondent Banks

• YMFG shall collect sufficient information on correspondent banks to fully understand their AML/CFT framework and assess the ML/TF risks posed by these relationships and take robust risk mitigation measures based on a risk-based approach.
• YMFG shall reject any deals and transactions involving shell banks or correspondent banks that affiliate with shell banks.

　*The above-mentioned policy shall fall within the scope of the banking business.

Training

• YMFG shall continuously carry out the training for executives and employees to establish business operations related to money laundering prevention and ensure its effectiveness.

Suspicious Activity Report

• YMFG shall monitor the transaction status with customers on a daily basis and promptly notify the authorities about suspicious customers and transactions detected.

Audit for the Status of Compliance

• YMFG shall audit the appropriateness of money laundering prevention system and make an effort to further improve the system.