Effective on June 27, 2023
Aizawa Asset Management Co., Ltd.
(Purpose)
Aizawa Asset Management Co., Ltd. (hereinafter referred to as Aizawa) has established the policy for Anti-Money Laundering and Combating the Financing of Terrorism (hereinafter referred to as “AML/CFT”) as follows and will contribute to the sound maintenance and development of the financial system by striving to prevent our customers, officers and employees from engaging in or being involved with money laundering and the financing of terrorism.
In order to build the risk management structure against money laundering and the financing of terrorism, Aizawa aims to build the AML/CFT structure by placing measures against money laundering and the financing of terrorism as one of the most important issues for its management strategy, based on the understanding that money laundering and the financing of terrorism may pose a significant managemental risk.
(Organizational structure)
Article 1. Aizawa places AML/CFT as the most important management issue and assigns its business administration department to oversee AML/CFT.
- Aizawa appoints its representative director as the officer in charge of measures against money laundering and the financing of terrorism.
- Aizawa will build the structure that can timely and appropriately provide necessary information to the officer in charge to allow the said officer to explain measures internally and externally against money laundering and the financing of terrorism at financial institutions, etc.
- The officer in charge will build a framework for cooperation between officers and departments pertaining to measures against money laundering and the financing of terrorism.
(Method to manage customers)
Article 2 When verifying transactions with customers, Aizawa will take appropriate measures in accordance with the concept of a risk-based approach. Aizawa strives to mitigate risks through saving the result of regular investigation and analysis on transactions with customers, performing risk assessments and continuously managing customers.
(Training policy for officers and employees and appropriate allocation for human resources and budget)
Article 3 Aizawa aims to raise importance and awareness of AML/CFT through coaching and training officers and employees, and the management will participate in training, etc. relevant to AML/CFT. Considering the importance of measures against money laundering and the financing of terrorism, Aizawa will make appropriate allocations of resources including assigning human resources with expertise and allocating necessary budgets to relevant departments.
(Auditing the status of compliance)
(Approach to report suspicious activity)
Article 5 Aizawa routinely conducts monitoring with the method defined by internal rules and immediately reports to authorities after properly analyzing detected suspicious activities.