Policy Against Money Laundering and Other Related Activities
The Kyoto Chuo Shinkin Bank (hereinafter the “Shinkin Bank”) has established the following policy, positioning the prevention of money laundering, terrorist financing, proliferation financing, and compliance with various domestic and international economic sanctions regulations as one of its key management issues. The Shinkin Bank aims to build and strengthen an effective management framework across the entire organization.
(1) Policy of the Group Against Money Laundering and Related Activities
The Shinkin Bank and its group companies recognize the importance of measures against money laundering and other related activities and will establish an appropriate management framework.
(2) Organizational Framework
The Shinkin Bank will appoint a chief officer responsible for taking overseeing measures against money laundering and other related activities, granting them sufficient authority to fulfill their duties. The Shinkin Bank will ensure the timely and appropriate collection of necessary information and establish a system capable of explaining its measures against money laundering both internally and externally.
In addition, a department dedicated to such oversight will be established, and appropriate resources shall be allocated to it, including the placement of personnel with expertise and the provision of a necessary budget. Through collaborative efforts including related departments, the Shinkin Bank will promote the enhancement of its response across the organization.
(3) Risk Management Based on a Risk-Based Approach
The Shinkin Bank will conduct risk identification and assessment to address immediate and pressing challenges of money laundering and other related activities, and carry out appropriate risk management based on risk-based approaches such as implementing mitigation measures. Moreover, the Shinkin Bank will regularly verify the effectiveness of its risk identification, assessment, and mitigation measures, and make revisions as necessary.
(4) Customer Due Diligence
The Shinkin Bank will conduct transaction verification based on relevant laws and regulations, ensuring appropriate customer due diligence while striving to eliminate business relationships with inappropriate customers, including anti-social forces. Moreover, in accordance with domestic and international regulations, the Shinkin Bank will appropriately carry out measures such as eliminating business relationships with sanctioned individuals and freezing assets.
The Shinkin Bank will implement continuous customer due diligence measures not only when establishing business relationships with new customers but also with existing customers.
(5) Reporting of Suspicious Transactions
The Shinkin Bank will implement appropriate transaction monitoring and filtering, and establish a framework to accurately detect, monitor, and analyze suspicious customers and transactions.
For detected suspicious transactions, the Shinkin Bank will establish a framework to take timely and appropriate measures and promptly report to the authorities based on relevant laws and regulations.
(6) Economic Sanctions Measures
In accordance with various domestic and international regulations concerning economic sanctions, the Shinkin Bank will appropriately carry out measures such as eliminating business relationships with sanctioned individuals and freezing assets.
(7) Correspondent Banking Due Diligence
The Shinkin Bank will appropriately collect and evaluate information on correspondent banks and, as necessary, implement appropriate measures based on the risk assessment of these correspondent banks. Furthermore, the Shinkin Bank will prohibit transactions with financial institutions that have no business substance and transactions involving highly anonymous accounts, both for the Shinkin Bank itself and its correspondent banks.
(8) Training of Officers and Employees
The Shinkin Bank will conduct appropriate and continuous training on measures against money laundering and other related activities for all officers and employees, tailored to their roles. Through such training, the Shinkin Bank aims to deepen the organization's overall understanding of these measures, while also striving to maintain and enhance the expertise of officers and employees and foster human resource development.
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'January 1, 2019
Kyoto Chuo Shinkin Bank
Revised on September 30, 2019 (Changed the term "subsidiaries and affiliated companies" to "group companies")
Revised on December 1, 2022 (Added prevention of proliferation financing and changed the policy name)
Revised on April 1, 2024 (Added and modified content related to economic sanctions measures)