Customer Acceptance Policy

1. Purpose

   This policy aims to ensure the proper operation of the financial services we provide and reduce the risk of fraud and financial crimes. Based on this policy, we will determine appropriate customer acceptance standards, thoroughly anti-money laundering (AML) and counter-terrorist financing (CFT), and manage the risk of sanctions violations, and comply with laws and regulations (Act on Prevention of Transfer of Criminal Proceeds, Foreign Exchange and Foreign Trade Act, the FATF Recommendations, etc.).

2. Scope

   This policy takes into consideration measures against money laundering and terrorist financing, proliferation financing risks, etc. (including the risk of violating sanctions), and applies to all of our new and existing clients (individuals, corporations and organizations). Our employees and business partners (including contractors) are obligated to comply with this policy.

3. Customer Acceptance Criteria
   1. Basic Acceptance Criteria

      We only accept customers who meet the following criteria:

      • Customers must complete identity verification and provide accurate information.
      • The purpose of the transaction and the source of funds must be clear and legitimate.
      • Use our services for lawful purposes.
      • Customers who are deemed to be at low risk of engaging in financial crime.
   2. Customers for whom acceptance is restricted or prohibited

      We restrict or prohibit transactions with customers who fall under any of the following:

      1. Sanctioned individuals and countries
         • Individuals, corporations, and organizations on sanctions lists such as those of the United Nations, OFAC (Office of Foreign Assets Control), the EU, and the Japanese government.
         • Customers who conduct transactions related to sanctioned countries such as North Korea, Iran, Russia, and Belarus.
      2. High-risk customers
         • Customers who are more likely to conduct suspicious transactions.
         • PEPs (Politically Exposed Persons), their relatives, associated companies and associates.
         • Customers whose sources of funds are unclear.
         • A corporation whose actual business operations cannot be confirmed shell corporation Customers who are conducting or are likely to be conducting transactions on behalf of a third party.
      3. Customers who are at risk of violating laws and regulations
         • Industries with a high risk of money laundering or terrorist financing (e.g. gambling, casinos, crypto assets clients, etc.).
         • Transactions suspected of impersonation or customers suspected of having falsified customer identification data.
         • Transactions with customers who reside or are located in specific countries, etc.
         • Customers who may violate laws and regulations.
4. Customer Acceptance Procedures

   We apply the following procedures when accepting clients:

   1. Customer Due Diligence (CDD)
      • Before starting a transaction, we conduct KYC (Know Your Customer) identity verification (including the beneficial owner in the case of a corporation).
      • Verify the purpose of the transaction and the source of funds, and conduct a risk assessment.
      • Conduct additional due diligence (EDD ) on high-risk customers.
   2. Sanctions List Screening
      • Check new and existing customers against sanctions lists to prevent transactions with sanctioned parties.
   3. Transaction monitoring
      • Even after transactions have begun, we continue to monitor for any unusual transactions.
      • If any suspicious transactions occur, we immediately discuss how to respond internally and promptly report the matter to the Financial Services Agency.
   4. Review of customer acceptance procedures
      • When new economic sanctions are implemented (or have been implemented), promptly review customer acceptance procedures to ensure they adequately reduce the risk of violating sanctions and make any necessary revisions.
5. Management of high-risk customers

   Certain customers are subject to more stringent monitoring and management.

   • Request additional identity verification documents, verify the relevant business background, and conduct additional due diligence (EDD) where necessary.
   • Compare with normal transaction patterns, and if there are any abnormalities, check the details, strengthen transaction monitoring, and take immediate action if any suspicious activity is found.
6. Continuous management of existing customers

   As a customer's situation may change, we take the following measures even after transactions have begun.

   • Customer information is updated regularly, once a year, and risk assessments are carried out on an ongoing basis.
   • Reassessing risks as trading patterns change.
   • Continue screening against the latest sanctions lists.
7. Education and Training

   In order to ensure the proper implementation of this policy, we provide the following training to all employees.

   • Conduct annual training on AML/CFT and sanctions risks.
   • Conduct practical training on KYC and CDD implementation procedures.
   • Conduct training on suspicious transaction criteria and reporting procedures.
8. Audits and reviews
   • The implementation of this policy is evaluated regularly through internal audits.
   • The contents of this policy are reviewed as necessary and revised with the approval of the Executive Committee or Board of Directors.
   • We revise it as necessary in response to amendments to laws and regulations and changes in the risk environment.

This Customer Acceptance Policy is an important guideline for ensuring compliance with AML/CFT, sanctions risk and regulatory requirements. It aims to maintain the integrity of the company and minimize the risk of financial crime through proper customer due diligence.