Response to Money Laundering and Terrorism Financing

Basic policy concerning money laundering and terrorism financing

In response to global regulatory tightening against money laundering and terrorism financing, targeted at financial institutions, etc. in recent years, the Company has positioned measures against money laundering and terrorism financing as a material issue in management strategies, etc. and has established the basic policy as follows.

- Organizational structure

The Company establishes a corporate system to prevent the use of its products and services provided to customers in money laundering and terrorism financing.

- Top management involvement

Senior management of the Company takes the lead and is directly involved in efforts to prevent money laundering and terrorism financing, as a material issue in management strategies, etc.

- Identification, evaluation and mitigation

The Company identifies the risks of money laundering and terrorism financing by product and service, form of transaction, country and region and customer attribute related to transactions, etc., evaluates the impact on the Company, and devises appropriate measures for mitigating risks depending on the degree of risk involved.

- Customer management

In accordance with the Act on Prevention of Transfer of Criminal Proceeds and other relevant laws, regulations, etc., the Company implements verification at the time of a transaction when contract application is made and when payment is accepted, makes records of the foregoing and uses these records to prevent money laundering and terrorism financing.

- Reporting of suspicious transactions, etc.

The Company sets forth procedures for reporting suspicious transactions, appropriately processes suspicious transactions, etc. detected through daily monitoring and promptly reports to the supervisory authority.

- Training for Management, employees, etc.

The Company provides education and training regarding money laundering and terrorism financing on a periodic basis, thereby encouraging Management, employees, etc. to acquire, foster and improve their knowledge and awareness.

- Management of affiliates

In a concerted effort throughout affiliated companies to prevent and eradicate organized crime, terrorism, etc., the Company is working to create a consistent framework to implement measures against money laundering and terrorism financing, thereby contributing to maintaining a sound financial system.

- Internal audit

The Company conducts internal audits on a periodic basis for the status of frameworks to prevent money laundering and terrorism financing. Based on the audit results, it works to strengthen its internal systems.

Measures to prevent money laundering and terrorism financing

To prevent money laundering and terrorism financing, the Company implements countermeasures in accordance with the Act on Prevention of Transfer of Criminal Proceeds (the “Act”) and other relevant laws, regulations, etc.
We appreciate your understanding and cooperation regarding measures to prevent financing to crime syndicate, terrorists, etc.

- Please cooperate with us in verification at the time of a transaction

We implement customer identity verification (name, address, date of birth, purpose of transaction, occupation, etc.) at the time of a transaction in accordance with the Act on Prevention of Transfer of Criminal Proceeds.

- Please update your information.

For customers using our credit cards, etc., please be sure to notify us of any change in your name, address, telephone number, place of employment, etc.

- Please cooperate with us in reverifying the purpose of transactions, etc.

Even if verification has already been conducted, depending on the content, status, etc. of transactions, we may reverify the purpose, content, etc. of transactions by telephone or postal mail.
You may also be asked to submit documents that can prove the content of the information you provide with us and/or identity verification documents.

- Please cooperate with us in verifying the content of the information on your residence card.

We ask non-Japanese customers to verify their national origin and period of stay and/or to submit a copy of their residence card or special permanent resident certificate.

– Restrictions on transactions, etc.

If we are unable to verify the above or if you are found to have lent your credit card to another person (including family member) or engaged in other inappropriate use, you may be disqualified from membership.
In addition, your existing transactions in products, services, etc. may also be restricted in accordance with the membership agreement, etc.