Compliance Policy for the Prevention of Money Laundering and Violations of Economic Sanctions
REVOLUT TECHNOLOGIES JAPAN Inc. (hereinafter referred to as the "Company") has positioned the prevention of money laundering, terrorist financing, proliferation financing (hereinafter referred to as "Money Laundering, etc.") and violations of economic sanctions as one of its most important management priorities, and will work on this issue company-wide in accordance with the following basic policy.
1. Establishment of a system to prevent money laundering and violations of economic sanctions
The Company will establish and strengthen systems, policies, procedures, plans, etc. to prevent money laundering, etc. and violations of economic sanctions.
2. Management Involvement
Management will take a proactive and responsible approach to preventing money laundering and violations of economic sanctions.
3. Risk assessment of money laundering and economic sanctions violations
We regularly identify and assess the risks we face related to money laundering, etc. and violations of economic sanctions, and implement and strengthen mitigation measures commensurate with those risks.
4. Customer Due Diligence
We conduct customer due diligence and identity verification procedures on a risk-based basis.
5. Sanctions Screening and Filtering
We will appropriately screen and filter out sanctioned parties.
6. Monitoring and reporting of suspicious transactions
We will conduct transaction monitoring to detect suspicious transactions, and when we detect any suspicious transactions, we will report them to the appropriate supervisory authorities.
7. Training
All officers and employees will regularly undergo appropriate training on the prevention of money laundering and violations of economic sanctions.
8. Document and Record Retention
The Company will properly retain documents and records related to the prevention of money laundering and violations of economic sanctions in compliance with the periods stipulated by laws and regulations.
9. Internal Audit
The Company will periodically conduct risk-based internal audits to verify the appropriateness and effectiveness of measures to prevent money laundering, etc. and violations of economic sanctions.