Policy on Anti-Money Laundering and Combating
Terrorist Financing and Proliferation Financing

The Hirogin Group sees its measures to combat money laundering, terrorist financing, and proliferation financing (hereinafter referred to as ML/TF/PF) as key components of its social responsibility. All relevant Group sections will work in concert to implement and maintain these measures at all times, backed by the active and vigorous involvement of the management team.

  1. Risk identification and assessment
    Our Group will identify and assess its own risks in relation to ML/TF/PF, taking appropriate measures to effectively reduce these risks based on a risk-based approach.
  2. Customer due diligence
    For the purpose of management based on this risk-based approach, our Group will implement customer due diligence measures (including ongoing due diligence) based on the results of its risk assessments. The Group will categorically refuse to engage in transactions with customers for whom specified customer due diligence measures, such as obtaining knowledge on customers (KYC), are impossible, or who refuse to cooperate with such measures.
  3. Suspicious activity reports
    Our Group will establish procedures allowing us to identify and report suspicious activities promptly and appropriately.
  4. Economic sanctions and asset freezing
    Our Group will perform appropriate filtering and screening of customers and transactions in a timely manner, eliminate transactions with parties subject to economic sanctions, and take measures including asset freezing.
  5. Correspondent bank management
    Our Group will gather information on and perform risk assessments of our correspondent banks and take appropriate measures based on the risks. Our Group will not engage in transactions with shell banks without actual operations and with correspondent banks doing business with shell banks.
  6. Training
    Our Group will provide all personnel with appropriate, ongoing training in measures intended to combat ML/TF/PF.
  7. Verifying effectiveness
    Our Group will monitor the status of measures intended to combat ML/TF/PF, verify their effectiveness, and seek to improve and strengthen related management efforts.