Anti-Money Laundering Policy

Hokuhoku Financial Group, Inc. and our group companies*1 (hereinafter referred to as "Hokuhoku FG") recognizes the importance of anti-money laundering, counter  financing of terrorism, counter-proliferation financing (hereinafter referred to as "AML/CFT/CPF*2") and the compliance with the Foreign Exchange Act and its regulations, etc., and hereby establishes the policy as follows.

1.Organizational Structure and Operation Policy

Hokuhoku FG recognizes prevention of money laundering, terrorist financing and proliferation financing (hereinafter referred to as "ML/TF/PF") and the compliance with the Foreign Exchange Act and its regulations, etc. as one of critical management tasks, and establishes organizational structure to prevent ML/TF/PF under the proactive involvement of the administration. Also, Hokuriku FG clarifies the roles of executives and employees, and its relevant departments cooperate to collect information on the issue and exercise appropriate measures.

2.Risk-Based Approach

For the purpose of ML/TF/PF prevention and the compliance with the Foreign Exchange Act and its regulations, etc., Hokuhoku FG identifies and assesses current ML/TF/PF risks in a timely and appropriate manner and implements risk mitigation measures based on the risk-based approach.

3.Customer Due Diligence (CDD)

Hokuhoku FG properly investigates and verifies customer information and transaction details based on laws and regulations with continuous CDD.

4.Reporting of Suspicious Transactions

If transaction is determined as suspicious, Hokuhoku FG promptly submits suspicious transaction reports to relevant authorities.

5.Management of Correspondent Banks

Hokuhoku FG collects sufficient information from correspondent banks and implements measures against AML/CTF/CPF and the compliance with the Foreign Exchange Act and its regulations, etc. in a timely manner.

6.Training for Executives and Employees

Hokuhoku FG  continuously conducts training related to AML/CFT/CPF and the compliance with the Foreign Exchange Act and its regulations, etc.  to improve knowledge and awareness of executives and employees.

7.Audit for the Status of Compliance

Independent auditors regularly audit the effectiveness of the framework of AML/CFT/CPF and the compliance with the Foreign Exchange Act and its regulations, etc. Based on the results,  Hokuhoku FG constantly applies efforts for its further improvement.

 

(* 1) Group companies subject to the policy

The Hokuriku Bank,Ltd.

The Hokkaido Bank,Ltd.

Hokuhoku Tokai Tokyo Securities Co.,Ltd.

Hokugin Lease Co.,Ltd.

Hokuriku Card Co.,Ltd.

Hokuhoku Capital Co.,Ltd.

Dogin Card Co.,Ltd.

(* 2) Money laundering refers to "act of disguising the source of revenue obtained by crime and disguising it not to be criminal profit", terrorist financing refers to "act of providing terrorists with necessary funds for execution" , and proliferation financing refers to "act of offering funds and financial service for persons subject to asset freezing because of the participation in developing, possessing and exporting weapons of mass destruction" . Neglecting money laundering allows criminal earnings to be used for future criminal activities and will let criminal organizations　dominate legitimate economic activities. Therefore, preventing money laundering  is an important issue domestically and globally. Furthermore, money laundering has become internationalized, sophisticated and complicated in recent years, and world-wide cooperation is strongly required to prevent it.

(* 3) The compliance with the Foreign Exchange Act and its regulations, etc. refers to the complying with Foreign Exchange and Foreign Trade Act and Act on Prevention of Transfer of Criminal Proceeds, and their government ordinances, ministerial ordinances and regulations, and of norms requested in conventional wisdom.