Anti-Money Laundering and Financial Crime Policy

The Nanto Bank and affiliated companies (hereinafter referred to as “the Bank”) recognizes the importance to prevent money laundering and countering terrorist financing, proliferation financing, corruption, and bribery (hereinafter collectively referred to as “money laundering”) and has implemented an enterprise-wide Anti-Money Laundering (“AML”) program.

１．Organizational Structure
（１）
The Bank is committed to combatting money laundering and takes all necessary steps to comply with relevant AML laws and regulations. The Bank has established the necessary rules and procedures and shall continue to ensure that there is sufficient resources and personnel with expertise to carry out this commitment.
（２）
The Bank has established a dedicated department responsible for overseeing and preventing money laundering. Additionally, the Bank has appointed a dedicated individual to lead this department. The department will actively coordinate with other departments, working collectively to combat money laundering.
２．Risk-Based Approach

The Bank shall identify and assess the risk of money laundering and take risk-based approach to determine appropriate counter-measures.

３．Customer Due Diligence

The Bank shall implement appropriate customer identification programs in accordance with the applicable laws and regulations. The Bank shall continue to monitor the customer transactions and behaviors, and take all reasonable and necessary actions if suspicious activities were identified.

４．Suspicious Transaction Reporting (STR)

The Bank shall promptly file a STR to the regulator if the Bank identified the suspicious activity which warranted the filing through transaction monitoring or reporting from the branches.

５．Correspondent Banking Management

The Bank shall ensure the collection of sufficient information from correspondent bank counterparties to conduct the risk assessment, and implement appropriate counter-measures based on the identified risks. Transaction with banks without a physical presence (commonly known as shell banks) or have associations with shell banks are strictly prohibited.

６．Training

The Bank shall provide appropriate trainings to all employees (including management) to maintain and enhance their understanding of money laundering prevention.

７．Policy Review and Audits

The Bank shall periodically conduct internal audit of its AML program to strengthen the control, taking into account the findings from the audit.

８．Sanctions and Asset-Freezing Measures

The Bank shall take necessary actions when sanctioned individual/ entity is identified. These include a termination of transactions, asset-freezing and other measures pursuant to relevant domestic and overseas regulations.

９．Bribery and Corruption

The Bank is committed to comply with both the letter and the spirit of Anti-Bribery and Corruption regulatory regimes. The Bank maintains zero-tolerance policy towards receipt/ provision of bribes. Furthermore, employees (including management) must exercise sound judgement to ensure that any exchange of gifts or entertainment is appropriate for the occasion and reasonable in a broader societal context.

To provide guidance in this matter, the Bank has established a Guideline for gifts/ entertainment which all employees (including management) are required to follow. The Bank is committed to continuously promote ethical conduct throughout the organization.