Anti-Money Laundering / Countering the Financing of Terrorism / Countering Proliferation Financing Policy
The Bank of Kyoto Group establishes the governance structure and sets the following policies, procedures and approaches in order to comply with all legal and regulatory requirements and obligations to implement appropriate Anti-Money Laundering / Countering the Financing of Terrorism / Countering Proliferation Financing (AML/CFT/CPF) measures for ensuring business adequacy.
1.Management Policy
The Board acknowledges AML/CFT/CPF as a critical management issue and establishes the AML/CFT/CPF framework to respond to emerging regulatory policy and any other relevant affairs in a timely and appropriate manner as an integrated organization.
2.Organizational Framework
The Director of the Risk Management Division is appointed as the Anti-Money Laundering Compliance Officer. The Risk Management Division is responsible for the implementation of AML/CFT/CPF policies and procedures in coordination with other relevant departments and business units throughout the Group.
3.Risk-Based Approach
The Group adopts a Risk-Based Approach in identifying and assessing Money Laundering / Terrorist Financing / Proliferation Financing (ML/TF/PF) risks which the Group is exposed, and in implementing the appropriate countermeasures designed to mitigate those risks.
4.Customer Due Diligence
The Group establishes Know Your Customer (KYC) procedures to understand customer attributes and receive customer verifications at the Time of Transaction in a timely and appropriate manner. The countermeasures are updated based on the results of the periodic investigation and analysis on customer transaction records.
5.Sanctions and Asset Freezing
All transactions are screened against various sanctions lists and any transactions found to involve specially designated individuals/entities will be blocked. The Group implements appropriate measures to ‘freeze’ accounts, funds, or other assets of designated individuals/entities in which a targeted government or authority has an interest.
6.Reporting of Suspicious Transactions
The Group establishes procedures to ensure prompt reporting of suspicious transactions and activity detected by the bank’s monitoring and screening systems and personnel to all relevant authorities.
7.Correspondent Banking Due Diligence
The Group aims to collect sufficient information related to correspondent banks in order to evaluate and implement appropriate countermeasures to mitigate any ML/TF/PF risks presented by correspondent banking relationships. The Group and its correspondent banks are prohibited from transacting with shell banks and accounts with high anonymity.
8.Training
The Group aims to provide regular and targeted trainings to enhance bank personnel’s understanding of their respective roles and responsibilities, and expertise in carrying out the Group AML/CFT/CPF policies.
9.Monitoring and Testing
The Group aims to continually strengthen the Group AML/CFT/CPF policies, procedures and systems through routine and comprehensive assessments conducted by the independent Internal Audit Division.