Anti-Money Laundering and Countering the Financing of Terrorism

The Shinsei Bank Group (hereinafter, the “Group”) positions the measures on anti-money laundering and countering the financing or terrorism (hereinafter, “AML/CFT”) as one of the most important business management challenges for the Group and works on organizing the Group-wide frameworks.
To combat money laundering and terrorism financing, Shinsei Bank takes the measures described below. In addition, each of the Group member companies takes similar measures according to their respective situation concerning the risk of money laundering and terrorism financing.

1. Risk assessment

Specify and assess the risk of money laundering and financing of terrorism at each company based on the concept of the risk-based approach, while paying attention to laws, ordinances, and other rules in Japan and documents issued by the Financial Action Task Force (FATF), the Basel Committee on Banking Supervision, and other international organizations. Take risk mitigation measures that are appropriate for the risk being addressed.
Regularly examine the effectiveness of risk identification and assessment practices and risk mitigation measures and review them as needed.

2. Customer identification and due diligence

Conduct customer identification before entering into transactions pursuant to relevant laws and ordinances, practice proper customer due diligence, and endeavor to eliminate inappropriate transaction relationships with customers including those with antisocial forces.

3. Transaction monitoring, customer screening, and reporting of suspicious transactions

Give the authorities a suspicious transaction report immediately if a transaction is judged to fall under suspicious transactions based on an abnormality found in the customer identification process conducted before entering into a transaction or during transaction monitoring or customer screening or based on a report made by business promotion divisions/branches.

4. Targeted financial sanctions and asset-freezing measures

Eliminate transaction relationships with the parties that are subject to targeted financial sanctions and appropriately take asset-freezing and other measures pursuant to domestic and overseas regulations and so forth.

5. Management of customers with correspondent contract

Appropriately collect information on customers who have entered into a correspondent contract with the Bank and assess their AML/CFT frameworks.
Shinsei Bank and its customers who have entered into a correspondent contract with the Bank are prohibited from having transactions with shellbanks and from having transactions using through accounts with a strong level of anonymity.

6. Training for officers and employees

Endeavor to provide guidance and training to officers and employees to deepen their knowledge and understanding of AML/CFTmeasures and to equip them with expertise and to ensure their suitability according to their roles.

7. Continuous improvement

Regularly check the effectiveness of AML/CFT frameworks and endeavor to keep improving them based on the results of such checks.