Basic Policy on Anti-Money Laundering and Countering the Financing of Terrorism

The SBI Group believes it to be its basic mission to contribute to the maintenance and development of society while responding to the needs of various stakeholders as a member of society, based on its managerial philosophies of “having a sound ethical sense of value” and “fulfilling social responsibilities.”
In recent years, international regulations on the prevention of money laundering and terrorism financing (“ML/TF”) have been strengthened, and the SBI Group regards these issues as one of its most important management challenges.
Based on the SBI Group’s Basic Policy, SBI Remit Co., Ltd. (the “Company”) will also establish its basic policy as follows. In conjunction with developing a framework based on this Basic Policy, the Company will strive to continuously improve such framework and take anti-money laundering measures, as well as measure for countering the financing of terrorism (“AML/CFT Measures”).

1．Development of Framework for AML/CFT Measures

The Company strives to develop and maintain a framework to prevent the products and services it provides from being used for ML/FT purposes.

2．Involvement by Management

The Company’s management regards AML/CTF Measures as a key issue for management strategy and will address this issue in an independent and proactive manner.

3．Identification, Assessment and Mitigation of Risks Related to ML/TF

The Company will utilize a risk-based approach to verify risks related to the products and services offered, transaction types, countries and geographic areas of transactions, customer attributes, and other relevant factors, identify risks related to ML/TF, assess the impact of the identified risks on the SBI Group, and will then take appropriate measures to mitigate any such risks based on the results thereof.

4．Customer Due Diligence

The Company strives to eliminate business relationships with inappropriate customers, including anti-social forces and those subject to sanctions, by implementing identification and other procedures in accordance with the relevant laws and regulations, determining whether or not to accept a customer, and conducting appropriate customer management.

5．Monitoring and Reporting of Suspicious Transactions

The Company conducts appropriate transaction monitoring to detect suspicious transactions. If any suspicious transactions are detected, they are reported to the relevant supervisory authority.

6．Preservation of Documents, Records, Etc.

The Company preserves documents and records, etc. related to AML/CFT Measures in an appropriate manner in accordance with the relevant laws and regulations.

7．Utilization of IT Systems and Data Management

With a view to enhancing the sophistication and efficiency of its AML/CFT Measures, the Company is committed to utilizing IT systems and Fintech, as well as ensuring appropriate data management.

8．Continuous Improvement

The Company will conduct periodic reviews and internal audits of its framework for AML/CFT Measures and strive to continuously improve the same. In addition, the Company will strengthen its management system in a forward-looking manner to ensure that the Company will not be utilized for ML/TF activities in the future.

9．Training of Officers and Employees

The Company endeavors to deepen the knowledge and understanding of officers and employees in departments involved in AML/CFT Measures through training, etc., so that such officers and employees will have the expertise and suitability, etc. appropriate to their roles.

Established on June 12, 2019
Revised on September 30, 2022

(This translation is provided for customer understanding only. In the event of any differences between the translated version and the Japanese version hereof, the Japanese version shall take precedence.)