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Anti-Money Laundering, Counter Financing of Terrorism, and Counter-Proliferation Financing Policy
Bank of Communications Co., Ltd., Tokyo Branch (hereinafter referred to as "the Branch") hereby establishes the following basic policy to prevent money laundering, financing of terrorism and proliferation financing (hereinafter collectively referred to as "Money Laundering etc.").
１．Management Policy
The Branch positions the prevention of Money Laundering etc. as one of its most critical management priorities. We are committed to continuous review and enhancement to build an effective risk management framework. At the same time, we will collaborate closely with domestic and international relevant authorities, pay close attention to domestic and global laws, regulations, and financial crime trends, and live up to the trust placed in us as a financial institution.
２．Organizational Framework
The Branch adopts a Three Lines of Defense model. Under the proactive leadership of management, we formulate policies, procedures, and plans regarding measures against Money Laundering etc., promote collaboration and cooperation among all departments, and conduct appropriate operations and management to ensure the effectiveness of these measures.
３．Risk-Based Approach
Based on the risk-based approach, the Branch identifies and assesses the risks related to Money Laundering etc. that the Branch faces, taking into account external information such as the "National Risk Assessment of Money laundering and Terrorist Financing" and "National Risk Assessment of Proliferation Financing", and implements mitigation measures commensurate with those risks.
４．Legal and Regulatory Compliance
In accordance with the Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act and other related laws and regulations, the Branch conducts and records verification at the time of transaction, and effectively utilizes these records to prevent Money Laundering etc.
５．Economic Sanctions and Asset Freezing
The Branch eliminates transactions with subjects of economic sanctions through methods such as filtering. Furthermore, we continuously enhance a system to appropriately implement verifications regarding measures such as asset freezing.
６．Reporting of Suspicious Transactions
The Branch establishes procedures for reporting suspicious transactions, appropriately processes suspicious transactions detected through day-to-day monitoring, and promptly submits suspicious transaction reports to the supervisory authorities.
７．Prohibition of Anonymous and Fictitious Accounts
The Branch does not engage in transactions involving highly anonymous accounts or accounts under fictitious names.
８．Employee Training
The Branch deepens the knowledge and understanding of its directors and employees through regular education and training regarding the prevention of Money Laundering etc., strives to foster and enforce awareness, and works to secure and develop personnel with the expertise and suitability appropriate for their respective roles.
９．Anti-Bribery and Anti-Corruption
The Branch strives to ensure that its directors and employees possess high professional ethics. Based on the purpose of related laws and regulations, the Branch establishes compliance guidelines prohibiting bribery as well as entertainment and gifts that exceed socially accepted standards, and all directors and employees shall comply with these guidelines.
１０．Review of Compliance Status and Auditing
In addition to timely reviews of the prevention framework for Money Laundering etc. conducted by the head of AML management, the Branch conducts regular audits by an independent internal audit department, and strives to further improve its internal framework based on the results of such audits.
１．Management Policy
The Branch positions the prevention of Money Laundering etc. as one of its most critical management priorities. We are committed to continuous review and enhancement to build an effective risk management framework. At the same time, we will collaborate closely with domestic and international relevant authorities, pay close attention to domestic and global laws, regulations, and financial crime trends, and live up to the trust placed in us as a financial institution.
２．Organizational Framework
The Branch adopts a Three Lines of Defense model. Under the proactive leadership of management, we formulate policies, procedures, and plans regarding measures against Money Laundering etc., promote collaboration and cooperation among all departments, and conduct appropriate operations and management to ensure the effectiveness of these measures.
３．Risk-Based Approach
Based on the risk-based approach, the Branch identifies and assesses the risks related to Money Laundering etc. that the Branch faces, taking into account external information such as the "National Risk Assessment of Money laundering and Terrorist Financing" and "National Risk Assessment of Proliferation Financing", and implements mitigation measures commensurate with those risks.
４．Legal and Regulatory Compliance
In accordance with the Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act and other related laws and regulations, the Branch conducts and records verification at the time of transaction, and effectively utilizes these records to prevent Money Laundering etc.
５．Economic Sanctions and Asset Freezing
The Branch eliminates transactions with subjects of economic sanctions through methods such as filtering. Furthermore, we continuously enhance a system to appropriately implement verifications regarding measures such as asset freezing.
６．Reporting of Suspicious Transactions
The Branch establishes procedures for reporting suspicious transactions, appropriately processes suspicious transactions detected through day-to-day monitoring, and promptly submits suspicious transaction reports to the supervisory authorities.
７．Prohibition of Anonymous and Fictitious Accounts
The Branch does not engage in transactions involving highly anonymous accounts or accounts under fictitious names.
８．Employee Training
The Branch deepens the knowledge and understanding of its directors and employees through regular education and training regarding the prevention of Money Laundering etc., strives to foster and enforce awareness, and works to secure and develop personnel with the expertise and suitability appropriate for their respective roles.
９．Anti-Bribery and Anti-Corruption
The Branch strives to ensure that its directors and employees possess high professional ethics. Based on the purpose of related laws and regulations, the Branch establishes compliance guidelines prohibiting bribery as well as entertainment and gifts that exceed socially accepted standards, and all directors and employees shall comply with these guidelines.
１０．Review of Compliance Status and Auditing
In addition to timely reviews of the prevention framework for Money Laundering etc. conducted by the head of AML management, the Branch conducts regular audits by an independent internal audit department, and strives to further improve its internal framework based on the results of such audits.
Bank of Communications Co., Ltd., Tokyo Branch