Basic policy on transactions under the Foreign Exchange and Foreign Trade Act

Our company considers the prevention of money laundering and terrorist financing (AML/CFT), as well as the maintenance of international peace and security, to be of the utmost importance. To strictly comply with the Foreign Exchange and Foreign Trade Act (FEFTA) and other relevant laws and regulations, we request all customers to conduct transactions in accordance with the following basic policy.

1. Exclusion of transactions with sanctioned individuals and entities

We strictly refuse transactions with any “individuals or entities subject to measures such as asset freezing” and any other sanctioned targets designated by the Japanese Government, the United Nations, other international organizations, or respective national governments. For corporate customers, this policy applies equally if the beneficial owner falls under the category of a sanctioned target.

2. Restrictions on transactions related to specific countries and regions

We cannot accept transactions destined for, originating from, or substantially involving countries and regions restricted or prohibited by FEFTA and other relevant laws and regulations (e.g., North Korea, Iran, Russia, and Belarus).

3. Strict measures against prohibited import items from North Korea (16 specific items)

In accordance with United Nations Security Council resolutions and economic sanctions against North Korea under FEFTA, the import or intermediary trade of specific goods originating from or shipped from North Korea is strictly prohibited. We conduct rigorous verification regarding the settlement of import payments and related transactions for 16 specific prohibited items, including marine products such as shrimp, squid, and crab. This strict verification applies even to indirect imports or settlements routed through third countries (such as neighbouring Asian nations). Any transaction suspected of involving these prohibited items will be categorically refused.

4. Legality of the purpose of funds

Funds transferred through our company must never be intended for the transfer of criminal proceeds (money laundering), terrorist financing, or the proliferation of weapons of mass destruction (CPF).

5. Requests to customers: cooperation with investigations and transaction restrictions

Submission of documents: In accordance with laws, regulations, and our internal rules, we may request detailed confirmation regarding the purpose of your transaction, the source of funds, and your relationship with the recipient. Particularly for trade-related settlements, we may require the submission of relevant documents such as commercial invoices, import quota certificates, certificates of origin, and bills of lading.

Restriction or suspension of transactions: If you are unable to cooperate with our verification requests, if there are discrepancies in your declared information, or if we deem a transaction inappropriate based on reasonable grounds, we may take measures such as refusing the transaction, suspending or cancelling the remittance, or suspending your account without prior notice.

We apologise for any inconvenience this may cause and kindly ask for your understanding and cooperation in our ongoing efforts to prevent international financial crimes.