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Anti-Money Laundering & Counter-Terrorism Financing Policy

The policy of Apex Co., Ltd. (hereinafter referred to as the “Company”) regarding anti-money laundering and counter-terrorism financing (hereinafter referred to as “AML/CFT”) measures is as follows:

 

1. Purpose

Our company is committed to preventing and combating money laundering and terrorist financing activities. This Anti-Money Laundering (AML) policy outlines our measures and procedures to detect, prevent, and report any suspicious transactions or activities related to money laundering.

2. Customer Due Diligence (CDD)

Due Diligence: Following the law “Act on Prevention of Transfer of Criminal Proceeds (「犯罪による収益の移転防止に関する法律」)”, we will conduct customer identification for the following specified transactions.

  ①Cash transactions exceeding 2 million yen

    ※Even for transactions below 2 million yen, if it is apparent that a transaction is split to reduce the transaction amount per transaction, it will be considered as one transaction.

  ②Transactions requiring special attention

    ※Transactions other than those mentioned in 1, which require special attention in customer management, including:
・Transactions that are suspected of being related to money laundering.
・Transactions conducted in a significantly different manner from the usual patterns of similar transactions.

3. Preventative Measure

For the following specified transaction types the delivery will be by Restricted Delivery Mail (本人限定郵便):

  ①Transactions exceeding 2 million yen paid by Bank Transfer (銀行振込)

    ※Even for transactions below 2 million yen, if it is apparent that a transaction is split to reduce the transaction amount per transaction, it will be considered as one transaction.

  ②Transactions requiring special attention

    ※Transactions other than those mentioned in 1, which require special attention in customer management, including:
・Transactions that are suspected of being related to money laundering.
・Transactions conducted in a significantly different manner from the usual patterns of similar transactions.

4. Countermeasures against crimes related to the Consumption Tax Law using precious metals

In recent years there has been a trend of smuggling gold bullion purchased overseas into Japan and selling the smuggled precious metals within Japan to gain profits using the consumption tax law. Our company does not engage in the business of buying back precious metals from the general public (買取業), we buy only from known verified sources, thus there is no risk of our company becoming involved in such illegal activities

5. Transaction Monitoring

We have effective transaction monitoring procedures to detect and investigate any suspicious activities. This includes monitoring transaction patterns, frequency, and amounts, as well as assessing any unusual or inconsistent behavior that may indicate potential money laundering activities.

6. Reporting Suspicious Activities

Internal Reporting: Our employees are required to report any suspicious transactions or activities promptly to our designated AML officer or our compliance department.

External Reporting: If we have reasonable grounds to suspect money laundering or terrorist financing, we will file suspicious transaction reports (STRs) or suspicious activity reports (SARs) with the appropriate regulatory authorities in accordance with Japanese laws and regulations.

7. Ongoing Training and Awareness

This Anti-Money Laundering Policy is communicated to all employees. We provide training and awareness programs to our employees to ensure they understand their responsibilities and obligations regarding AML procedures. This includes educating about potential red flags and indicators of money laundering and promoting a strong culture of compliance throughout our company.

8. Record Keeping

For a period of time, as required by Japanese law, we maintain records of transactions, and related documents. These records are securely stored and accessible only for required law enforcement investigations.

9. Cooperation with Authorities

We are committed to cooperating with relevant regulatory authorities and law enforcement agencies in their efforts to combat money laundering and terrorist financing. If required, we will provide requested information, support investigations, and maintain open lines of communication with the appropriate lawful authorities.

10. Compliance Monitoring and Review

We conduct periodic internal reviews and assessments of our AML policies, procedures, and controls to ensure their effectiveness and compliance with evolving regulatory requirements. Any identified weaknesses or gaps will be addressed promptly through appropriate corrective actions.

 

This Anti-Money Laundering Policy will be communicated to all employees, and its implementation and effectiveness will be regularly reviewed and updated as necessary to address new risks and regulatory changes.

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