Guidelines for Anti-Money Laundering and Combating the Financing of Terrorism

[Provisional Translation]
The original texts of the Guidelines are prepared in Japanese, and this translation is only provisional. The translation is to be used solely as reference material to aid the understanding of the Guidelines and is subject to any future changes. Guidelines for Anti-Money Laundering and Combating the Financing of Terrorism March 31, 2026 Financial Services Agency

I General Concepts ...................................................... - 1 - I-1 Risk-based approach ............................................... - 1 - I-2 Financial institutions’ AML/CFT measures............................. - 3 - (1) ML/FT risk control framework..................................... - 3 - (2) Involvement and understanding of the Board ......................... - 3 - I-3 Roles of industry associations and central institutions .................... - 4 - I-4 Supervisory actions................................................. - 5 - II Risk-Based Approach .................................................. - 6 - II-1 Risk-based approach ............................................... - 6 - II-2 Identification, assessment, and mitigation of risk ........................ - 6 - (1) Risk identification ................................................ - 7 - (2) Risk assessment .................................................. - 8 - (3) Risk mitigation .................................................. - 8 - (i) Risk mitigation measures ......................................... - 8 - (ii) Customer due diligence (CDD)..................................... - 9 - (iii) Transaction monitoring and screening .............................. - 12 - (iv) Record keeping ................................................ - 13 - (v) Suspicious transaction reporting (STR) ............................. - 13 - (vi) IT systems .................................................... - 14 - (vii) Data governance ............................................... - 15 - (4) Considerations when making cross-border transfers and similar transactions- 16 - (i) Cross-border wire transfers and similar transactions ................... - 16 - (ii) Financing and extending credit involving trade-based finance............ - 17 - (5) New technologies ................................................ - 18 - III Evaluation and Review of the ML/FT Risk Control Framework and its Effectiveness￾19 - III-1 Formulation, implementation, evaluation, and review of AML/CFT policies, procedures and programs (PDCA)......................................... - 19 - III-2 Involvement and understanding of the Board .......................... - 20 - III-3 The Board and control: three lines of defense .......................... - 21 - (1) First line of defense .............................................. - 22 - (2) Second line of defense ............................................ - 22 -

(3) Third line of defense ............................................. - 23 - (4) Management of Outsourcing of ML/FT Risk Management ............. - 24 - III-4 Group-wide risk control framework.................................. - 24 - III-5 Human resource development ....................................... - 26 - IV Monitoring and Public Private Partnership ............................. - 27 - IV-1 Monitoring by the Financial Services Agency .......................... - 27 - IV-2 Public private partnership and cooperation with relevant authorities ...... - 28 -

I General Concepts
I-1 Risk-based approach
The basic requirements on anti-money laundering and combating the financing of terrorism (“AML/CFT”) in Japan, such as identification and verification at the time of transactions, are prescribed in the Act on Prevention of Transfer of Criminal Proceeds (“Criminal Proceeds Act”, or APTCP), the Foreign Exchange and Foreign Trade Act (“Foreign Exchange Act”), and other relevant laws and regulations. Financial institutions licensed or registered to conduct operations under the Banking Act, the Insurance Business Act, the Financial Instruments and Exchange Act, and other laws that introduce legislation for each type of business in the financial industry are legally regarded as a “specified business operator” under APTCP, as well as “Banks, etc.” or “Financial institutions, etc.” under the Foreign Exchange Act, and therefore are subject to relevant requirements prescribed in such laws and regulations. Since a financial system is a network of various flows of funds in the diversified forms of remittances, settlements, and money transfers conducted by the financial institutions, in order to ensure the soundness of the entire financial system, it is vital that individual financial institutions participating in the financial system shall build and maintain solid risk control framework commensurate with their operations and roles in the financial system. AML/CFT measures that a financial institution should take are substantially influenced by ever-changing international affairs, as well as the constantly evolving actions by other financial institutions responding to such external circumstances. Financial institutions need to swiftly respond to the changes in such circumstances and their corresponding risk profiles, and effectively maintain their money laundering and the financing of terrorism (“ML/FT”) risk control framework. Implementing such swift and effective countermeasures requires financial institutions to appropriately identify and assess the ML/FT risks they face in a timely manner – including risks relating to their customers’ operations –, and to undertake mitigation measures commensurate with those risks, a so called risk-based approach. The risk-based approach for ML/FT risk control framework is established as a central principle of the Financial Action Task Force (“FATF”) Recommendations, and has equally been an established practice in major developed countries. With the need for swift and effective measures, the risk-based approach is a minimum standard that financial institutions participating in Japan’s financial system should implement. As seen in past cases in which inadequate AML/CFT measures led financial institutions to

face large fines from foreign authorities or the termination of correspondent banking arrangements from their foreign counterparties, AML/CFT prevention measures are facing increased scrutiny due to terrorism and other threats to the international community Appropriate actions by Japan’s financial system in response to such calls are necessary. In particular, those financial institutions engaging in foreign remittances need to sufficiently respond to supervision by foreign authorities and other international AML/CFT developments. As the threat of terrorism has spread across borders, financial institutions shall establish effective risk control framework for terrorist financing with the awareness that their products and services can be abused as tools for terrorist financing. For example, in the case where a financial institution conducts a transaction with a non-profit organization, it is important for financial institutions to be aware that they are at risk of being exploited for terrorist financing depending on the nature and areas of their activities, while presuming that not all non-profit organizations are inherently higher-risk customers, and to take necessary risk mitigation measures taking into account the National Risk Assessment (Japanese NRA as provided for in APTCP) and the analyses by the FATF. Financial institutions shall establish appropriate risk control framework, including measures addressing the financing of proliferation of weapons of mass destruction, taking into account relevant foreign and domestic laws and regulations such as the Foreign Exchange Act and the Act on Special Measures Concerning International Terrorist Assets Freezing. To this end, the Board of a financial institution needs to take the lead in establishing cross￾regional and cross-departmental governance, and under this governance, related departments need to continue their efforts to improve AML/CFT measures, in order to ensure that these measures against money laundering and terrorist financing function effectively in the business divisions, which are points of contact with customers. Financial institutions should develop in their business strategies forward-looking actions for strengthening their AML/CFT measures for preventing the future misuse of their products and services. They should also fulfill their accountability to a wide range of stakeholders including customers and authorities with regard to their policies, procedures, programs as well as their implementation status by disclosing relevant data. The Financial Services Agency (“FSA”), with necessary supervisory measures, shall monitor the AML/CFT measures of each financial institution, share the outcome with financial institutions, and urge them to enhance their risk control framework. The Guidelines clarify the required actions and to be implemented by each financial institution and how the FSA shall conduct monitoring going forward. The Guidelines also explain the roles of industry associations
and central institutions and

coordination with the authorities, with a view in particular to helping financial institutions with small sizes or limited scope of transactions to develop effective risk control frameworks. I-2 Financial institutions’ AML/CFT measures (1) ML/FT risk control framework Financial institutions are required to identify and assess their ML/FT risks based on an overall group-wide understanding of their products and services, transaction types, countries and geographic areas, and customer attributes, and to implement mitigation measures commensurate with such risks, taking into account their business environment and strategies as well as their risk tolerance levels. In order to swiftly undertake measures commensurate with those risks that reflect ever￾changing international circumstances and the evolving responses by other financial institutions, it is vital not only to address individual cases or problems, but rather, with the involvement and understanding of the Board, to undertake holistic forward-looking evaluation including the necessity for reforming their risk control framework, and develop a group-wide effective ML/FT risk control framework. To address this perspective, the FSA will constantly review the Guidelines. Financial institutions are also required to establish and maintain their risk control framework reflecting the contents of related laws and regulations and the Guidelines, not focusing exclusively on compliance, under the guidance of control functions, with those regulations and the Guidelines and checking technical compliance with them. While there are differences between the risks of money laundering and the financing of terrorism – such as the purpose, size, and value of those transactions as well as the countries or geographic areas that need caution upon executing those transactions – the basic frameworks required to maintain the soundness of the financial system do not differ fundamentally among those transactions. The Guidelines therefore explain AML and CFT simultaneously. (2) Involvement and understanding of the Board In establishing the aforementioned control framework, it is essential for the Board to be involved in countermeasures, such as taking the initiative in establishing governance for control, rather than leaving it to the relevant departments to deal with the risk, based on the understanding that the risk of money laundering and terrorist can have serious repercussions for the financial institution overall.

The proactive engagement and leadership of the Board would be necessary, for example, in conducting a forward-looking gap analysis, taking cross-organizational measures involving multiple divisions, and strategically hiring and training their personnel and allocating resources according to their expertise and experience. In order to disseminate AML/CFT initiatives to all executives and employees, it would also be important to demonstrate the Board’s proactive commitment toward AML/CFT and convey their messages, such as by taking into account AML/CFT in the performance evaluation of employees. It is vital for the Board to increase the awareness of AML/CFT based on an appropriate understanding of ML/FT risks, and promote more advanced cross-organizational measures by their top-down initiatives. After all, the responsibility for fulfilling accountability outlined in I-1 above for strengthening the ML/FT risk control framework is to be primarily assumed by the Board. I-3 Roles of industry associations and central institutions Information gathering by an individual financial institution with respect to advanced practices on a risk-based approach or international developments in AML/CFT may sometimes qualitatively and quantitatively be limited. As the methods of ML/FT are constantly changing, it may be especially difficult for financial institutions with small volume or limited scope of transactions to accumulate sufficient information or expertise by themselves. In order to enhance the level of the entire Japanese financial system, it is essential for industry associations, central institutions, etc., to take central and guiding roles in improving their member financial institutions’ ML/FT risk control framework, in coordination with the authorities. This includes sharing of information and casesto which financial institutions should refer, providing support for creating risk control framework, promoting industry￾wide joint operations via appropriate shared IT systems, and encouraging broader user understanding. In cases in which a central institution conducts transactions for the customers of its member financial institutions via outsourcing or agency relationships, or in cases an internationally operating bank is relied upon by other banks to undertake their customers’ foreign remittances, such a central institution or internationally-operating financial institution is also required to establish the necessary and adequate control framework to undertake AML/CFT in accordance with the risk-based approach.

I-4 Supervisory actions
Keeping Japan’s financial system sound and immune from ML/FT is extremely important, and the FSA, as the financial authority, properly conducts the monitoring of financial institutions’ measures and progress in developing AML/CFT measures in accordance with the Guidelines. If such monitoring and other measures identify problems with a financial institution’s ML/FT risk control framework, including the inadequate implementation of required actions in the Guidelines, the FSA makes financial institutions improve by taking necessary administrative actions prescribed in relevant laws such as reporting orders and business improvement orders, referring also to Supervisory Guidelines that are stipulated for each industry type. In addition, the FSA prepares and publishes documents that show the concept of “the required actions” described in the Guidelines and the FSA's approach to monitoring, as necessary, to promote understanding among financial institutions. Financial institutions need to implement AML/CFT measures while paying attention to such documents. The amended Criminal Proceeds Act, which came into effect in October 2016, introduced risk assessment by the government and specified business operators. The Guidelines provide the required actions, encompassing those requirements under the amended Criminal Proceeds Act and other necessary or expected measures, with the purpose of ensuring financial institutions’ effective risk identification, assessment, and mitigation with a risk-based approach. Even if not described in the Guidelines, financial institutions are subject to the Supervisory Guidelines for each business category and to other regulatory documents relating to all specified business operators, in particular, Points to Note regarding APTCP and List of Reference Cases of Suspicious Transactions, published by the FSA. Effective AML/CFT measures such as a risk-based approach are an international requirement for financial institutions, and therefore they should pay adequate attention to the documents issued by the FATF, the Basel Committee on Banking Supervision, and other international bodies. The Guidelines apply to firms that fall under the category of the specified business operators as prescribed in Article 2, paragraph 2 of APTCP and are under the supervision of the FSA with the exception of the entities listed in item 48 of the said paragraph (“[a] financial institution[s]”).

II Risk-Based Approach
II-1 Risk-based approach
The risk-based approach in combating money laundering and terrorist financing means that financial institutions, etc. identify and assess their own inherent risks of money laundering and terrorist financing, and implement risk mitigation measures in order to effectively reduce such risks to within their risk appetite. The types and techniques of ML/FT are constantly changing in conjunction with crime and other underlying trends, as well as broader socio-economic conditions such as industry and employment conditions, demographic movements, legal systems, new forms of transaction types due to advances in information technology (“IT”), and the globalization of the economy and financial services. With the changes in the ML/FT methods, AML/CFT measures should be constantly enhanced. The increased convenience and speed of information transfer in recent years has exacerbated the risk that financial institutions that have fallen behind in implementing the enhancements will be exploited for ML/FT. Financial institutions need to take effective actionsthrough the risk-based approach, in order to appropriately identify and assess ML/FT risks by themselves and prioritize and swiftly improve ML/FT risk control framework commensurate with the risks. The risk-based approach has become an international standard, as set out in the Financial Action Task Force (“FATF”) Recommendation 1 as an underlying principle in the whole document. (Note) (Note) The FATF Recommendations state that “countries should identify, assess, and understand the money laundering and terrorist financing risks for the country” and financial institutions “should be required to take appropriate steps to identify and assess their money laundering and terrorist financing risks” for products and services they handle, requiring both countries and financial institutions to respectively implement risk-based approaches. II-2 Identification, assessment, and mitigation of risk It is important under the risk-based approach to consider necessary actions against ML/FT risks in stages, for instance by categorizing them in stages of risk identification, assessment, and mitigation.

(1) Risk identification
Risk identification is a process to identify ML/FT risks faced by a financial institution through comprehensive and specific risk evaluation of the products and services offered, transaction types, the countries and geographic areas of transactions, customer attributes, and other relevant factors, and is the starting point of a risk-based approach. In order to conduct a comprehensive and specific verification of risk that an entity faces, it is necessary to consolidate internal information and conduct analysis from a company-wide perspective. Therefore, it is necessary for the Board to take the initiative in ensuring cooperation and collaboration among all related departments, rather than leaving it to the department in charge of countermeasures against money laundering and terrorist financing. When undertaking such evaluation, financial institutions must appropriately consider the NRA and the analyses conducted by foreign authorities and industry associations. Based on these considerations, it is important to take into account both the analyses commonly applicable to every sector and those specific to a certain sector, capturing both characteristics. Further, such analyses tend to focus on general matters that are common to multiple financial institutions. Financial institutions therefore need not only to refer to these analyses, but also to comprehensively and specifically capture the characteristics of their businesses and identify the risks they themselves face. Required actions for a financial institution A financial institution shall:
i. Identify the ML/FT risks it faces by comprehensively and specifically evaluating risks
of the products and services offered, transactions types, the countries and geographic areas of transactions, customer attributes, and other relevant factors, while considering the results of the national risk assessment.
ii. When conducting a comprehensive and specific evaluation, take into account the
financial institution’s specific features, such as the geographic attributes of its business region, business environment, and management strategy.
iii. When evaluating the countries and geographic areas of transactions, comprehensively
evaluate the possibility of direct and indirect transaction relationship, including the high-risk countries and geographic areas designated by the FATF and domestic and foreign authorities, and understand the risks.
iv. When offering new products and services, or conducting transactions using new
technologies/those with new characteristics, prior to their initiation, evaluate the AML/CFT risks associated with such products and services, including the effectiveness of the risk control framework of its alliance partner, other partners, outsourcing contractor and companies being acquired.

v. Conduct comprehensive and specific evaluation of ML/FT risks with the Board taking
the lead in ensuring coordination and collaboration among all relevant departments. (2) Risk assessment Risk assessment is a process to assess the level of impact on a financial institution of the ML/FT risks identified in the preceding (1), and formulates the basis for specific actions such as mitigation measures. The risk assessment therefore needs to reflect the characteristics of the financial institution’s business environment and the business strategy. As the risk assessment is directly linked to the specific details of risk mitigation measures and the (re)allocation of resources, it needs to be conducted in a firm-wide and consistent manner with the involvement of the Board. Required actions for a financial institution A financial institution shall:
i. Establish an enterprise-wide policy and specific methods for its risk assessment, and
conduct assessments of the ML/FT risks identified in "(1) Risk Identification" above based on factual, concrete and objective evidence in accordance with the said policy and methods.
ii. In making the assessment in (1) above, consideration should be given to the analysis of
the status of Suspicious Transaction Reporting.
iii. Analyze the status of suspicious transactions reported, for example, quantitative
information such as the number of reports should be analyzed by division, location, reporting factors, detection scenario, etc., and utilized for risk assessment.
iv. Document the results of the risk assessment, and utilize them for developing measures
necessary for risk mitigation.
v. Conduct the review of the risk assessment regularly, at least once a year, as well as
when an event such as the occurrence of new risks and the introduction of new regulation that may have a significant impact on AML/CFT measures occurs.
vi. Involve the Board in the processes of risk assessment, and obtain approval from the
Board for documenting the results of the risk assessment.
(3) Risk mitigation
(i) Risk mitigation measures
Risk mitigation is a process to conduct measures to mitigate a financial institution’s ML/FT risks and dictates the effectiveness of the institution’s ML/FT risk control framework. Under a risk-based approach, financial institutions are required to collect and verify information about specific customers’ profiles and activities, compare that information with the results of risk assessment conducted in accordance with aforementioned (1) and (2), and

determine and implement effective measures to mitigate those identified risks. (Note) (Note) In the Guidelines, “customer due diligence” (“CDD”) refers to, among other mitigation measures, a series of processes in which a financial institution collects and verifies information about specific customers and their activities and transactions in light of the results of its own risk assessment, compares that information with the results of the risk assessment, and determines and implements effective measures necessary to mitigate those identified risks. Apart from the approach that focuses on each customer, there are other approaches that focus on each transaction to analyze and detect unusual transactions. It is effective to combine both approaches for risk mitigation. Risk mitigation measures must be implemented according to the level of the risks posed by each individual customer and their transactions. Enhanced measures are required when a financial institution finds high risks based on its own criteria, whereas simplified measures are allowed when the financial institution finds lower risks. Each financial institution should, in accordance with risks it face, consider and implement the risk mitigation measures individually and specifically for each customer and transaction. In addition to the items listed in the Guidelines, financial institutions are required to devise mitigation measures commensurate with their risks while also referring to information provided by relevant domestic and foreign authorities and case examples shared through their industry associations. Required actions for a financial institution A financial institution shall:
i. Collect and verify information about customers and their activities and transactions,
compare that information with the results of risk assessment, and determine and implement effective measures to mitigate those identified risks.
ii. Undertake enhanced mitigation measures in cases where ML/FT risks are high,
commensurate with the level of risks posed by individual customers and their transactions, in accordance with policies, procedures, and programs developed by the financial institution.
iii. Examine updated cases and information from domestic and foreign authorities and
industry associations, as well as the items listed in the Guidelines, and then undertake mitigation measures commensurate with the risks the financial institution faces. (ii) Customer due diligence (CDD) As noted above, “customer due diligence” (“CDD”) in the Guidelines is, among other mitigation measures, a series of processes in which a financial institution identifies and assesses ML/FT risks with regards to a specific customer, reviews the information about the

customer and their transactions in light of the results of risk assessment, and determines the measures necessary to mitigate the identified risks, and is the core element of risk mitigation measures. When a financial institution transacts with a customer, it is vital that it collects and verifies fundamental information about the customer, such as who the individuals or entities including legal arrangements or its beneficial owners are, what they do, why they would like to conduct transactions, and where their funds come from. It then needs to consider and implement appropriate mitigation measures based on such information collected and verified. The processes of CDD may be expediently categorized into three stages: the start, continuation, and end of the business relationship. Each financial institution should determine and implement appropriate mitigation measures at each of the stages according to the level of risks posed by the individual customers and their transactions. A financial institution shall conduct customer risk assessments for all customers, taking into account the information confirmed in these processes, as well as their size, characteristics and business status. Financial institutions, etc. should implement risk-based enhanced customer management (Enhanced Due Diligence: EDD) for customers that they assess to be at high risk of money laundering and terrorist financing, including those who conduct transactions with foreign Politically Exposed Persons (PEPs) (Note 1) and specified countries (Note 2). On the other hand, when it is concluded that the risk is low, consideration should be given to the efficient execution of transactions by conducting Simplified Due Diligence (SDD) in accordance with the risk. (Note 1) Foreign PEPs as defined in each item of paragraph 3, Article 12 of the Order for Enforcement of APTCP and Article 15 of the Ordinance for Enforcement of APTCP. (Note 2) Jurisdictions as specified in each item of paragraph 2, Article 12 of the Order for Enforcement of APTCP. Required actions for a financial institution A financial institution shall:
i. Formulate a customer acceptance policy, based on the risk identification and
assessment of the institution, to systematically and specifically identify and determine high-risk customers and transactions and required actions for them.
ii. When formulating the customer acceptance policies in i. above, consider customers’
and beneficial owners’ occupations and business activities and other various information such as their backgrounds, assets and incomes, sources of funds, countries/regions of residence, products and services of their use, and their forms of transactions.
iii. Seek reliable evidence when surveying information relevant to a customer and its

beneficial owner and the purpose of transaction, including identity information of the customer and beneficial owner and other information such as the occupation and business details, personal history, the state of assets and incomes, source of funds, country/region of residence, etc.
iv. Comply with laws and regulations related to Japanese and other foreign sanctions, such
as by screening the names of customers and their beneficial owners with sanctions lists compiled by the relevant authorities, and take other necessary measures according to the risks involved.
v. Establish a framework to properly detect high-risk customers in accordance with the
size and characteristics of the financial institution, by utilizing reliable databases and systems or other reasonable measures.
vi. Conduct customer risk assessment for all the customers based on the results of the
assessment of the risk of ML/FT for products/services, transaction types, countries/geographic areas, customer attributes, etc. (risk assessment to be conducted in II-2 (2)), and determine the mitigation measures to be taken in accordance with the customer risk assessment.
vii. For customers determined to be of high ML/FT risk, apply enhanced due diligence
(EDD) measures in accordance with the customer risk including the following:
a. Obtain additional information in accordance with the risk, especially that of customer’s state of assets and incomes, purpose of transactions, occupation, title, and source of funds; b. Obtain the approval of senior management for transactions with such customers;
c. Enhance transaction monitoring by tightening the threshold for transactions
conducted by such customers and increase the frequency of periodic reviews of CDD information, in accordance with the risk; and d. Examine the need to assign stricter customer risk ratings for other customers with similar attributes.
viii. Additional measures, such as understanding the actual business status and geographic
areas, etc., should be taken prior to the start of transactions or when conducting large transactions, in cases where there is a high risk, such as where the customer's business, geographic area, etc., is deemed to be irrational in light of the purpose of transactions, transaction pattern, etc.
ix. For customers determined to have low ML/FT risk, give due consideration for smooth
execution of transactions by implementing simplified due diligence (SDD) measures taking into account the nature of the risk, such as varying the scope, methods, and frequency of investigation and updating of customer information, while taking into account the characteristics of such risk. Raising the threshold for monitoring transactions conducted by such customers may also be considered. (Note 1) (Note 2) (Note 1) Even in this case, financial institutions must comply with the laws and regulations of Japan and other jurisdictions applicable to such transactions. (Note 2) FATF and BCBS cite routine and small transactions by individuals as examples of transactions that do not require EDD.

x. In addition to the required actions in “(v) Suspicious transaction reporting (STRs)”
listed below, implement ongoing CDD measures including the following:
a. Develop and implement ongoing CDD policies that include the scope and frequency of the review on customers information taking into account the results of the institution’s risk assessment and transaction monitoring with respect to transaction types and customer attributes in particular; b. Continually review the appropriateness of the scope and methods of the due diligence conducted for each customer in light of the customer’s transaction status as well as the results of transaction monitoring;
c. Appropriately manage the records of investigations, including the communication
with the customer, and share these with the relevant executives and employees; d. Revisit customer information promptly when certain events occur that are assumed to increase the risk of each customer. In addition to this, the frequency of periodic customer data refresh should be different depending on the risk of the customer. ; and e. Review and, as appropriate, update the customer risk rating and apply risk mitigation measures based on customers’ risk attributes obtained in the process of ongoing CDD. Further, conduct transaction monitoring reflecting the customer risk rating result determined through ongoing CDD.
xi. For customers and transactions with which CDD measures a financial institution
determines to be adequate cannot be completed, including cases where the customer refuses to provide requested CDD information, consider appropriate measures to eliminate the risk, such as rejecting the transaction. In such instances, financial institutions are required to assure that the customer or transaction are not refused or rejected without a legitimate reason and that AML/CFT requirements are not used as an excuse for rejecting the customer. (iii) Transaction monitoring and screening In addition to CDD that focuses on individual customers, there is another approach for ensuring the effectiveness of risk mitigation measures, which focuses on the transactions to reduce risks through analysis of the actual transactions and the detection of unusual transactions and ones subject to sanctions. It is essential for financial institutions to implement these approaches in combination to further increase the effectiveness of risk mitigation measures. Required actions for a financial institution
i. A financial institution shall establish and maintain an appropriate control framework
for monitoring transactions in accordance with the risk in order to detect transactions, etc. that would lead to detecting and reporting of suspicious transactions. Such framework would at minimum cover the followings:
(a) Set scenarios and thresholds that reflect its own risk assessment result

(b) Analyze the characteristics of the transactions for which a STR has been filed (line of business, geographic areas, etc.) and the effectiveness of the current transaction monitoring method (scenarios, threshold, etc.) based on the results of detection according to the criteria in (a) above and the status of STR, etc., and enhance the transaction monitoring method. (c) Implement appropriate risk mitigation measures according to the level of suspicion of detected transactions and trends in ML/FT risks, etc.
ii. A financial institution shall establish and maintain an appropriate control framework
for filtering transactions to detect sanctioned transactions. Such framework would at minimum cover the followings:
(a) Ensure that the sanctions lists are up-to-date, effectively managed to screen the details of transactions (such as, but not limited to: remittance destination, parties involved in transactions, including their beneficial owners, import/export items), and that the criteria for detecting sanctioned items are reviewed and set at an appropriate frequency according to risk. (b) Take necessary measures to comply with laws and regulations pertaining to Japan and other foreign or international sanctions regimes according to their business profile and risk, such as screening a customer without delay when economic sanctions are designated by sanctions regimes such as United Nations Security Council resolutions. (iv) Record keeping The customer identification records and transaction records maintained by financial institutions not only provide the status and results of their CDD, but also represent essential information for submitting required data to the authorities and for determining the necessity for filing a suspicious transaction report. Required actions for a financial institution
i. A financial institution shall maintain the records necessary to implement appropriate
AML/CFT measures, including evidence relevant to customers’ KYC, etc. information as well as the records of transactions and communication with the customers. (v) Suspicious transaction reporting (STR) Suspicious transaction reporting (STR) is a legal obligation under APTCP. Being “specified business operators” under the Act, financial institutions are required to fulfill their obligations to report suspicious transactions. In addition, suspicious transaction reports can be utilized to strengthen their ML/FT risk control framework by analyzing them together with other indicators.

Required actions for a financial institution
A financial institution shall:
i. Establish programs for reviewing potentially suspicious transactions and determining
whether STR is necessary, by comprehensively taking into account specific information available to the institution including customer attributes and circumstances of transaction and by this way meet legal obligations and utilize the STR-related information to strengthen the financial institution’s risk control framework.
ii. Establish programs for monitoring, detecting and analyzing suspicious customers and
transactions, utilizing IT systems/procedures fit for the business operations of the financial institution.
iii. In determining whether STR is necessary or not, consider: customer attributes; a
foreign PEP status; business activity of the customer; the countries and geographic areas involved in transactions; the nature of the transaction, such as the amount and number of transactions in comparison with the customer attributes and business profile; and other circumstances, while taking into account the results of the National Risk Assessment and its Follow-up Report, the Reference Cases on Suspicious Transactions, and FI’s submitted STR cases.
iv. Review and file a STR appropriately a transaction’s nature such as an ongoing
transaction with an existing customer or a one-off transaction with a walk-in customer.
v. Establish a framework to promptly file a report once a transaction is determined to be
suspicious.
vi. Evaluate the effectiveness of risk mitigation measures for the transactions that have
been reported as suspicious, and review, and modify, if necessary, the mitigation measures applied to similar types of transactions.
vii. For customers who are determined to be at high risk, review their risk rating, and apply
risk mitigation measures as appropriate.
(vi) IT systems
Utilizing IT systems including software enables a financial institution an integrated management of various information associated with the transactions with their customers, such as products and services, transaction types, countries and geographic areas, and customer attributes. In addition, the risk control framework could be thereby strengthened by proper operation of IT systems, which potentially lead to detecting unusual transactions from a large volume of transactions systematically and promptly, to set and adjust the scenarios and threshold used to detect the said unusual transaction flexibly in accordance with risk. In order to properly utilize an IT system for AML/CFT, it is important to establish well￾designed IT systems, evaluate their effectiveness, and update them on a timely basis. These

require evaluating the system from operational aspects, such as whether the scenarios and thresholds are adequate in light of risks being faced and whether the sanctions lists used for screening of the beneficiaries of remittances and goods imported/exported are up-to-date. Required actions for a financial institution A financial institution shall:
i. Examine the necessity of promptly introducing an IT system according to the size and
characteristics of the financial institution’s business operation, and implement the items listed in ii. to v. below for the system management.
ii. The Board shall analyze the workload related to the risk control framework of ML/FT
and consider the possibility of using IT systems for more efficient, effective and timely execution.
iii. In implementing IT systems as part of countermeasures against ML/FT, verify that the
design and operation of the IT systems adequately respond to trends in ML/FT risks and are consistent with the risk control framework undertaken by themselves. In addition, regularly review and enhance, as necessary, the system.
iv. Evaluate the effectiveness of the IT system by reviewing, through an independent
assurance process, such as internal and external audits.
v. Even in the case of outsourcing some process or using a joint system, analyze the
characteristics of its own business and accompanying risks, and determine if additional measures are necessary. (vii) Data governance The effectiveness of IT systems can only be ensured with the accuracy of data such as customer information, customer identification records, and transaction records, each of which is used in those IT systems. In addition to ensuring the accuracy of customer identification records and transaction records, financial institutions are required to appropriately manage data as a prerequisite for effective use of IT systems, by collecting and storing accurate data and organizing it into analyzable means. Required actions for a financial institution A financial institution shall:
i. Ensure the accuracy of customer identification records and transaction records and
appropriately manage data as a prerequisite for the effective use of IT systems, by collecting and storing accurate data and organizing it in a manner capable of analysis.
ii. Periodically validate integrity and accuracy of the data used for IT systems such as
customer information, customer identification records, and transaction records.
iii. Establish an appropriate data management method for collecting and storing data that
can be used for risk assessments and evaluation of the effectiveness of risk mitigation

measures, organizing it in a manner capable of analysis, and making it available for submission to authorities if required. The data includes the items below as well as the information in the customer identification records and transaction records:
a. Number of suspicious transaction reports filed (breakdown by country/geographic area, customer attribute, etc.); b. The numbers and contents, etc., of internal audits and training (including the numbers of employees obtained relevant qualifications); and
c. Reports to the Board on ML/FT risk control framework, and the records of their
discussions.
(4) Considerations when making cross-border transfers and similar transactions (i) Cross-border wire transfers and similar transactions When a financial institution handles foreign remittance by itself or through other financial institutions, it is required to undertake necessary measures such as screening of the transaction against the applicable sanctionslists of relevant jurisdictions, in accordance with the Foreign Exchange Act and other domestic and foreign laws and regulations regarding foreign remittance. It should be emphasized that cross-border banking services, such as foreign remittance, involve different ML/FT risks compared to domestic banking services that complete locally, in that it is more difficult for the financial institution to monitor the parties involved in foreign transactions. Financial institutions therefore need to consider such differences in risks as well as the trends of foreign regulations and international discussions, in order to adequately identify, assess, and mitigate risks. When financial institutions have correspondent banking arrangements with other financial institutions or handle cross-border remittance transactions on behalf of other financial institutions, the effectiveness of measures for mitigating ML/FT risks is dependent on effectiveness of ML/FT risk control framework of their counterparties to the arrangement. Hence, the financial institution is required to appropriately monitor the effectiveness of ML/FT risk control framework of its counterparties. In addition, financial institutions may be required to provide adequate explanation about their ML/FT risk control framework and details of mitigation measures to correspondent banks and outsourced financial institutions. Furthermore, even when a financial institution outsources foreign remittances to other financial institutions, the outsourcing institution is required to identify, assess, and mitigate the ML/FT risks associated with foreign remittances as is the case for other business that they conduct by themselves.

Required actions for a financial institution
A financial institution shall:
i. Evaluate the nature of foreign remittance under a risk-based structure of AML/CFT,
and take necessary measures in accordance with the risk-based approach.
ii. Ensure that the ordering or intermediary financial institution informs the intermediary
or beneficiary financial institution of the originator and the beneficiary information in accordance with international standards, so that the intermediary or beneficiary institution is aware of the risks involved in the foreign remittance. Where the information is missing, the intermediary or beneficiary institution is required to take adequate measures commensurate with the risk.
iii. When a financial institution enters into a correspondent banking arrangement in order
for it to process foreign remittances, implement the measures set out in Articles 9 and 11 of APTCP and Articles 28 and 32 of the Ordinance for Enforcement of APTCP. In addition, establish programs for confirming the ML/FT risk control framework of the respondent institution and conduct periodic reviews.
iv. Assess each risk of the correspondent relationship and outsourced financial institutions,
etc. taking into account items such as but not exclusively: geographic areas; customer attributes; business activities; ML/FT risk control framework, and stance of supervision by local competent authorities. When there is a specific event noted and thus emerging risk identified, review the risk assessment reflecting the information obtained through the monitoring of the correspondent relationship and outsourced financial institutions etc.
v. In monitoring correspondent relationships and outsourced financial institutions, etc., if
the risk assessment result in (iv) above indicates that the risk is notably high, monitor them as necessary to ensure the state of their ML/FT risk control framework.
vi. Not enter into or maintain a correspondent banking arrangements, if the respondent
institution is a shell bank or the respondent institution permits their accounts to be used by a shell bank.
vii. When undertaking cross-border remittances for other financial institutions, monitor
their ML/FT risk control methodology by questionnaire, on-site visit and/or other measures, including their customer identification/due diligence programs relating to cross-border remittances.
viii. Even when the originator and the beneficiary is not a direct customer, consider, as
necessary, not only screening against the sanctions list, but also conducting enhanced investigation in accordance with the risk identified, in cooperation with the correspondent bank and outsourcer financial institutions.
ix. When outsourcing cross-border remittances to other financial institutions, ensure
evaluating the nature of the cross-border remittances under the financial institution’s risk-based approach, and identify, assess and mitigate the associated ML/FT risks. (ii) Financing and extending credit involving trade-based finance Compared to domestic transactions, it is easy to abuse trade finance for illicit purposes

due to the fact that it is more difficult to verify the actual location of import/export transactions, and to transfer the proceeds of crime by disguising import/export transactions or paying an additional/different amount to the actual transaction/unit price. In addition, there is a risk goods could be used for a dual purpose specifically for the trade of materials for military use or illegal drugs through fraudulent statements of import and export. A financial institution needs to identify, assess, and mitigate specific risks appropriately, recognizing that financing and extending credit for import/export transactions pose such risks. Required actions for a financial institution A financial institution shall:
i. Identify, assess and mitigate the risks associated with the financing and extending of
credit related to import/export transactions, etc.; not only the risks of the country/region involved in the import/export transaction, but also the risks of the products to be traded, the content of the contract, the transportation route, the vessel to be used, etc., and the risks of the parties involved in the transaction, etc. (including the beneficial owner) shall be taken into consideration. (5) New technologies New technologies such as AI (artificial intelligence), block chain, and RPA (Note) are used in various phases of AML/CFT to improve the effectiveness of controls, including the identification and verification at the time of transactions and the detection and reporting of suspicious transactions. These new technologies are expected to be utilized to a greater extent in AML/CFT measures. It is important for financial institutions to examine the benefits of new technologies, as well as their effectiveness as necessary and explore the possibility of leveraging them based on their size, characteristics, and business content for the increased sophistication and streamlining of AML/CFT controls, taking into account the practices of other financial institutions and issues surrounding the introduction of new technologies. (Note) Robotic process automation: Using program or technology such as artificial intelligence to automate routine jobs such as document preparation and data input. Required actions for a financial institution A financial institution shall:
i. Examine the benefits and effectiveness of new technologies as necessary, explore the
possibility of leveraging them based on their size, characteristics, and business content for the increased sophistication and streamlining of AML/CFT controls, taking into account the practices of other institutions and issues surrounding the introduction of new technologies.

III Evaluation and Review of the ML/FT Risk Control Framework and its Effectiveness In order to ensure the effectiveness of AML/CFT measures, financial institutions are required to establish an effective ML/FT risk control framework by formulating their policies, procedures, and programs, and implement them consistently throughout the organization with the involvement of the Board. Financial institutions are required to regularly evaluate the effectiveness of their AML/CFT that are based on those policies, procedures and programs, and to make constant efforts to improve effectiveness of the AML/CFT measures based on such evaluation and through necessary revisions. In order to establish such firm-wide risk control framework, a robust governance structure must be built, with the understanding and active involvement of the Board, including the appointment of an executive with the responsibility and authority to implement AML/CFT measures, and clear definition of the roles and responsibilities of each division. In addition, a financial institution that forms a financial group or operates globally is required to formulate AML/CFT policies, procedures, and programs, and apply them consistently across the groups and globally, taking into account the differences in the business profiles of group entities, and the countries and geographic areas in which they operate. Furthermore, the effectiveness of AML/CFT measures depends on how well the executives and employees understand the policies, procedures, and programs. Financial institutions are required to ensure that employees have required expertise and fitness through recruitment and training. III-1 Formulation, implementation, evaluation, and review of AML/CFT policies, procedures and programs (PDCA) Financial institutions are required to prepare AML/CFT policies, procedures, and programs and disseminate them throughout the organization in order to establish an effective ML/FT risk control framework and to function effectively. Such policies, procedures, and programs must be designed to ensure the effectiveness of the AML/CFT measures commensurate with the risks the financial institution faces and clearly define the sequential processes of identifying, assessing, and mitigating the risks, taking into account the institution’s size and characteristics. In addition, a financial institution is required to evaluate the effectiveness of such policies,

procedures, and programs, and revise them on an ongoing basis.
To evaluate the effectiveness of each process of identification, assessment, and mitigation of risks, it is important that executives responsible for and divisions in charge of AML/CFT conduct regular monitoring, while the internal audit division verifies how executives and employees of each division and branch are familiarized with the institution’s AML/CFT measures. Based on the result of this evaluation, a financial institution is required to reexamine possibilities of further improvements in the measures for each process and risk control framework, and to enhance the policies, procedures, programs, and risk control framework for the identification, assessment, and mitigation of risks. Required actions for a financial institution A financial institution shall:
i. Formulate AML/CFT policies, procedures and programs considering the risks in light
of the business sector of the institution and geographic area in which it operates as well as the trend of ML/FT, and apply specific approaches and practices of customer acceptance policies, CDD, record-keeping and other processes in a consistent manner across the organization.
ii. Conduct ongoing evaluation on effectiveness of the policies, procedures, and programs
for identifying, assessing, and mitigating risks, taking into account the results of monitoring of each division and branch.
iii. Consider the need to improve risk mitigation measures, including whether or not to
offer such products/services, or to implement further measures, depending on the risk appetite of a financial institution and the impact on it, etc., by assessing residual risks after risk mitigation measures have been taken.
iv. Have the control division and internal audit division evaluate the effectiveness of the
risk control framework, taking into account internal information, whistle-blowing reports and questions from employees.
v. If, as the result of the aforementioned evaluation of effectiveness, possibilities of
further improvements are identified, enhance the policies, procedures, programs, and risk control framework, for the identification, assessment and mitigation of risks. III-2 Involvement and understanding of the Board The level of ML/FT risks faced by a financial institution varies according to the way it operates based on their business strategy. Therefore, ML/FT risks must be assessed in the context of the institution’s business strategy, as part of the processes of evaluating and reviewing risk appetite and resource allocation policy. As seen in the past cases involving large fines or termination of business relationship, failure

to implement effective AML/CFT measures leads to a management problem such as reputational damage. Furthermore, “tone at the top” is critical to increase the awareness of AML/CFT measures among the executives and employees including the business divisions. The Board must therefore have a keen awareness of AML/CFT based on proper understanding of the risks mentioned above, and demonstrate its commitment and clear policy, to promote enhancement of measures throughout the organization from the top down. In light of this, the Board of financial institutions, etc., shall take a leading role in promoting the enhancement of their own countermeasures against ML/FT. Required actions for a financial institution A financial institution shall:
i. Recognize AML/CFT as one of the most important strategic issues.
ii. Appoint an executive responsible for AML/CFT measures of the institution, granting
the authority necessary to fulfill the responsibilities.
iii. Establish programs by which necessary information is provided to the executive
responsible for AML/CFT in a timely and appropriate manner so that the executive can explain the financial institution’s AML/CFT measures to internal and external stakeholders.
iv. In view of the importance of AML/CFT, allocate adequate resources such as personnel
with expertise and sufficient budget to the division responsible for AML/CFT.
v. Establish programs for coordination between the executives and divisions involved in
AML/CFT.
vi. Ensure that the Board approves the design and review of policies, procedures, and plans
for countermeasures against ML/FT, and the Board takes the initiative in the implementation of such policies, procedures, and plans by receiving reports on a regular and ad hoc basis and holding discussions as necessary.
vii. Ensure that the Board participates or is otherwise proactively involved in AML/CFT
training for the Board and employees.
III-3 The Board and control: three lines of defense Financial institutions are required to establish effective ML/FT risk control framework in accordance with the size and characteristics of their business operations. It is important that the Board takes responsibility for defining the roles and responsibilities of the business divisions, control and audit divisions in the fight against ML/FT, and implement measures in a coordinated manner. One way of clarifying the roles and responsibilities of each division is defining the functions of business divisions, control and audit divisions under the concept of “three lines of

defense.”
In the following sections, the functions in the ML/FT risk control framework by financial institutions are defined under the concept of three lines of defense and required actions are provided. Each financial institution may formulate its risk control framework under a different model, including outsourcing, depending on the characteristics of its business operations. In such instances, those financial institutions are required to design programs that achieve the same level of effectiveness that is required with the required actions. (1) First line of defense The first line of defense (“the first line”) is the business division. Branches and the business divisions that are engaged in business activities serving customers are the front line to face ML/FT risks first and therefore play a primary role in prevention of ML/FT. In order for the first line to function effectively, all employees belonging to the first line must engage in day-to-day business operations with a correct understanding of ML/FT risks. Financial institutions are required to take measures necessary to promote the first line’s understanding of the ML/FT risks associated with their operations, in light of the nature of such operations, for example, by formulating and disseminating AML/CFT policies, procedures, and programs, and by providing training to raise awareness. Required actions for a financial institution A financial institution shall:
i. Ensure that all employees belonging to the first line have sufficient understanding of
the AML/CFT policies, procedures, and programs applicable to their division and duties, and properly implement the mitigation measures commensurate with the risks.
ii. Provide a clear and easy-to-understand description for employees of their obligations
and instructions in the AML/CFT policies, procedures, and programs, and communicate them with all employees of the first line. (2) Second line of defense The second line of defense (“the second line”) is control divisions such as compliance and risk control framework. The second line independently checks the autonomous risk controls by the first line, and at the same time supports the first line in implementing controls. For the purpose of AML/CFT risk control framework, control divisions include the main division in charge of AML/CFT, the system division responsible for transaction monitoring systems, and the human resources division in charge of hiring and retaining personnel with expertise.

In order to fulfill the roles for supporting and checking the first line, the control divisions are required to possess knowledge relating to business of the first line as well as correct understanding of the ML/FT risks inherent to the business. Required actions for a financial institution A financial institution shall:
i. Monitor independently whether the ML/FT risk control framework is functioning
effectively, for example, by checking compliance by the first line with AML/CFT policies, procedures and programs, and evaluating the effectiveness of mitigation measures implemented by the first line.
ii. Provide sufficient support to the first line, for example, by providing information and
responding to questions relating to ML/FT and by advising on specific measures.
iii. Clarify the roles and responsibilities of the division in charge of AML/CFT and all
other divisions involved in AML/CFT, and share the understanding of the roles and responsibilities of each division. In addition, establish a collaborative environment between the division in charge of AML/CFT and other divisions, and ensure close communication and coordination.
iv. Allocate employees with sufficient knowledge and expertise of AML/CFT to control
divisions.
(3) Third line of defense
The third line of defense (“the third line”) is the internal audit division. The internal audit division is required to independently verify whether the first line and the second line are functioning appropriately and whether there is any possibility for further enhancement on a regular basis. In addition, the internal audit division is required to independently give an assurance on the effectiveness of firm-wide AML/CFT policies, procedures, and programs; raise issues if any; and advise on the necessity for reviewing the policies, procedures and programs or for enhancing the measures. Required actions for a financial institution A financial institution shall:
i. Formulate an audit plan that includes the following items in an audit scope and conduct
audits adequately:
a. Appropriateness of the AML/CFT policies, procedures, and programs; b. The expertise and competency of employees in charge of implementing such policies, procedures, and programs;
c. The effectiveness of employee training;

d. The status of detection of unusual transactions in the business division; e. Operating status of IT systems including the effectiveness of detection standards; and f. The status of the implementation of risk mitigation measures for detected transactions and of STR.
ii. Ensure that the scope, frequency and approaches of audits are appropriate in light of
the ML/FT risks being faced.
iii. Take necessary measures for business operations other than those assessed to have high
risk. For example, instead of uniformly excluding such operations from the audit scope, conduct audits by adjusting the frequency and depth.
iv. Report the results of the internal audits conducted by the internal audit division to the
corporate auditors and the Board, and follow up on the audit results and advise on improvements.
v. Allocate employees with the sufficient knowledge and expertise of AML/CFT to the
internal audit division.
(4) Management of Outsourcing of ML/FT Risk Management Each financial institution may outsource ML/FT risk management operation, depending on the characteristics of its business operations. With respect to the management of various risks associated with outsourcing, it is a matter of course to comply with the provisions of related laws and regulations depending on their application and to pay attention to the supervisory guidelines for each business category. In addition, in the case of outsourcing the ML/FT risk management operation, in particular, the control framework of the outsourcing contractor for the outsourced operation should be verified from the viewpoint of achieving the same level of effectiveness that is required with “required actions.” Required actions for a financial institution A financial institution shall:
i. When outsourcing ML/FT risk management, verify the control framework of the
outsourcing contractor from the viewpoint of achieving the same level of effectiveness that is required with the "required actions". III-4 Group-wide risk control framework A financial institution that forms a financial group is required to formulate group-wide AML/CFT policies, procedures and programs, and apply them consistently across the group, taking into account the differences in the business sectors of group entities, and the countries and geographic areas in which they operate. In particular, where a financial group operates through overseas offices, it is required to

recognize the difference in the geographic, political, and other environments between Japan and the foreign jurisdictions, establish group-wide programs consistently and apply across the group in consideration of such differences to ensure the effectiveness of the AML/CFT measures. Moreover, it should be noted that differences in AML/CFT requirements and information protection regulations between Japan and foreign jurisdictions may make it difficult to share information necessary for effective implementation of AML/CFT measures. Therefore, a financial group that operates through overseas offices is required to establish risk control framework consistently applied on a group basis and exercise appropriate oversight of the business operators within the group, taking into account such differences as well as the practices of other financial groups that are operating globally. This is particularly relevant for financial groups in which their overseas operations represent a large proportion of their business or those which recognize the operations as strategically important, given rapidly increasing calls for stricter AML/CFT measures. Japanese offices of foreign financial groups are required to fulfill accountability to the Japanese authorities and other stakeholders for their ML/FT risk control framework of the group as a whole, and the status of transactions with Japanese financial institutions including correspondent banking relationships. Required actions for a financial institution A financial institution shall:
i. Formulate group-wide AML/CFT policies, procedures, and programs consistently
applied across the group, and implement customer acceptance policy, specific CDD measures and record-keeping standard in a consistent manner throughout the entire group, in consideration of its business profiles and geographic areas in which it operates.
ii. Establish programs for information sharing within the group required for group-wide
risk assessments and for ensuring the effectiveness of AML/CFT measures.
iii. Where a financial group operates through overseas offices, implement risk mitigation
measures appropriate for the group as a whole, in compliance with each AML/CFT regulation applicable to its corresponding overseas operations and by allocating personnel in line with the risks, based on the identification and assessment of risks visualized through these processes and inherent to each overseas office.
iv. Where a financial group operates through overseas offices, in order to implement the
AML/CFT measures consistently across the group in a timely and appropriate manner, establish programs that enable sharing of necessary information and consolidated risk control framework (including the development and update of necessary IT systems), including the information about the customers and transactions involved in unusual transactions and the results of analyses as well as the status of STR, based on proper

understanding of the information protection regulations applicable to overseas offices and the stance of local regulators. (The necessity of such programs must be understood when formulating a business strategy for overseas operation.)
v. Where a financial group operates through overseas offices, if the AML/CFT
requirements of the jurisdiction in which each overseas office operates are less strict than those of Japan, apply and implement the group-wide policies, procedures and programs to those overseas offices in a consistent manner. If this is not permitted by the local regulation, inform the FSA. (Note) (Note) If the requirements of a foreign jurisdiction are stricter than those of Japan, the local requirements must be followed.
vi. In the case of Japanese offices of foreign financial groups, fulfill accountability to the
authorities and other stakeholders for the ML/FT risk control framework of the group as a whole, and the status of transactions with Japanese financial institutions, including correspondent banking relationships. III-5 Human resource development In order to ensure the effectiveness of ML/FT risk control framework, employees of branches and various other divisions must have the expertise and competency required for their roles, to properly implement policies, procedures, and programs prescribed by the Board. Financial institutions are required to deepen their employee’s understanding of AML/CFT measures, and maintain and improve expertise and competency for the entire organization, by hiring and training employees with such expertise and competency necessary for their roles through provision of appropriate training (including the status of relevant qualifications obtained) on an ongoing basis. Required actions for a financial institution A financial institution shall:
i. Continually evaluate that the employees involved in AML/CFT measures have the
knowledge and expertise required for such role, along with the competency to properly implement the measures including the identification and verification at the time of transactions and other measures after training.
ii. In order to ensure that the employees have a proper understanding of specific CDD
procedures including the identification and verification at the time of transactions according to their role, provide easy-to-understand material that helps them become familiar with the procedures, and other appropriate training on an ongoing basis.
iii. Analyze and examine whether the contents of such training are consistent with the risks
being faced, whether they are in line with the latest laws and regulations, and information from domestic and foreign authorities and whether there is room for

improvement from the perspective of dissemination.
iv. Evaluate the effectiveness of training, by examining whether the procedures outlined
in the training content are being followed, and by following up with the employee. Review the number of participants, frequency, status, and content of training, etc., as necessary, taking into account any emerging risks.
v. Deepen the risk awareness of the business division, for example, by sharing the
information about the firm-wide STR status and providing responses to questions, and by ensuring the information be available to each employee within the business division. IV Monitoring and Public Private Partnership IV-1 Monitoring by the Financial Services Agency As noted earlier, the FSA effectively monitors AML/CFT measures that financial institutions undertake taking into account the Guidelines, shares the outcome from the monitoring with individual institutions and industries, urges them to enhance ML/FT risk control framework, and takes necessary supervisory actions. The FSA focuses on substantive ML/FT risks. Therefore, the FSA collects and integrates available information to identify and assess the ML/FT risks of each business category and those of each individual financial institution in respective industries, with a holistic review of the financial system. Based on the assessment, the FSA conducts effective and efficient monitoring by allocating resources according to the level of the identified and assessed ML/FT risks. In the aforementioned processes of identifying and assessing ML/FT risks across and within business categories, the FSA considers the characteristics of financial institutions and business categories such as: the variety of products and services, transactions types, countries and geographic areas, and customer bases, as well as international trend relating to ML/FT. The FSA utilizes these factors to conduct a forward-looking monitoring. In order to conduct the aforementioned identification, assessment and analysis of ML/FT risks, objective data such as quantitative and qualitative information are necessary. The FSA further improves the effectiveness of its risk-based monitoring by collecting the below￾listed information from financial institutions in addition to already available data, and conducting interviews or other qualitative researches about their internal control. In order to effectively conduct such monitoring, the FSA develops expertise of specialists including employees of the Local Finance Bureaus and increases the number of employees with expertise through further recruitment of external experts. ✓ Number of STRs filed (breakdown by country/geographic area, customer attribute, etc.);

✓ Implementation status of internal audits; internal and external training, that also include the status of relevant qualifications obtained by officers and staff employee; ✓ AML/CFT Risk assessment that a financial institution is required to prepare under this Guidelines; and ✓ Reports to the Board on ML/FT risk control framework, and the records of discussions. That information is also useful for a financial institution to conduct identification and assessment of its ML/FT risks under its risk-based approach. A financial institution is thus expected to accumulate, organize, and utilize information necessary for their risk analyses including information listed above to improve the effectiveness of its risk-based approach. The FSA proactively shares cases collected through the monitoring process and information obtained from foreign authorities with financial institutions and industry associations to improve the overall level of AML/CFT of Japanese financial institutions.
Article 3, paragraph 3 of APTCP stipulates that the National Public Safety Commission
publishes the Japanese NRA concerning the risks of transfer of criminal proceeds in Japan. The FSA, as the supervisory authority of financial institutions, monitors financial institutions with the risk-based approach, taking into account the NRA. IV-2 Public private partnership and cooperation with relevant authorities In order to address increasing ML/FT risks and ensure the soundness of Japan’s entire financial system, it is necessary, in addition to the actions of individual financial institutions, that relevant domestic and foreign authorities, industry associations, financial institutions, and other private companies coordinate and cooperate to address the ML/FT risks. In particular, it is important to follow developments on international discussions and advanced practices in order to swiftly address ever-changing ML/FT trends. However, that information may, in some cases not be easily obtained by an individual financial institution, and thus information gathering by the individual institution may be inefficient for accumulating the knowledge to address the ML/FT risks. Under such circumstances, the FSA enhances information collection through increased coordination with industry associations, relevant ministries and agencies, and foreign authorities, and shares with financial institutions good practices obtained through the coordination and the useful cases obtained through monitoring activities. In addition to the coordination with business associations, the FSA engages in and undertakes ongoing dialogue with individual financial institutions, in order to facilitate continuous examination of AML/CFT-related issues, solutions, and improvement among financial institutions and industries.

Meanwhile, industry associations need to play a central role in providing member financial institutions with information on the latest trends, issues and actual cases or possible solutions to address the issues, and overseas useful practices regarding AML/CFT, and in supporting the implementation and the improvement of AML/CFT for those financial institutions. Furthermore, in improving the efficiency of ML/FT risk control framework, it is important to promote and enhance measures such as the introduction of new technologies and joint operation by outsourcing, in various areas such as CDD, risk assessment, and transaction monitoring and screening, besides information sharing as mentioned above. At the same time, to further facilitate smooth communication between the public and the private sector, the FSA continues to review its approaches of monitoring and outreach reflecting discussions with industry associations and individual financial institutions. These activities by the FSA need to be operated effectively in coordination with relevant ministries and agencies in Japan. In particular, monitoring on foreign remittances would be enhanced in its effectiveness and efficiency by coordination with the Ministry of Finance with respect to its foreign exchange inspections under the Foreign Exchange Act. It is also beneficial to exchange information and engage with foreign authorities. In these ways, with proactive and close engagement and coordination with industry associations, individual financial institutions, relevant ministries and agencies, and foreign authorities, the FSA will continuously ensures effective AML/CFT measures in Japan. February 6, 2018 Issued April 10, 2019 Revised February 19, 2021 Revised July 19, 2021 Revised November 22, 2021 Revised March 31, 2026 Revised and current