We, the Awa Bank, Ltd., declare hereinafter that we recognize financial institutions are responsible for preventing money laundering (ML) and the financing of terrorism (FT), then we conduct our business in compliance with following policies.

1. Organizational Structure
    As anti-money laundering and combating the financing of terrorism (AML/CFT) is one of the most important business issues, we designate the responsible officer and   supervising division in charge of AML/CFT and clarify their roles. We establish and develop an appropriate framework in cooperation with relevant divisions.
2. Compliance
   We comply with applicable laws and regulations related to AML/CFT, including those of other relevant countries/areas in transactions.
3. Handling Financial Crimes
   We strictly deal with crimes such as unauthorized use of financial services, (e.g. opening or using unauthorized accounts and selling or buying accounts) in cooperation with investigative authorities, by the closure of account or elimination of the transaction.
4. Customer Acceptance Policy
   We stipulate our policy of accepting or rejecting customers in the “Regulations Concerning Customer Acceptance Policy.” Based on this policy, we eliminate transactions with persons subject to high risk of ML/FT (e.g. transactions with persons suspected of identity theft).
5.  Risk Management
   We implement appropriate risk management based on risk-based approach, including the appropriate identification and assessment of ML/FT risks and the risk mitigation measures commensurate with the risks.
6. Reporting of Suspicious Transactions
   

   We cooperate with financial authorities and investigative authorities and utilize information to conduct appropriate risk management. We appropriately report suspicious transactions to the authorities.

7. Economic Sanctions and Asset Freeze
   We eliminate sanctioned transactions by filtering transactions and/or name screening. We also establish and maintain an appropriate control framework for screening appropriately when sanctions regimes designate such as asset freezes.
8. Management of Correspondent Banks
   With respect to correspondent banks, we make efforts to collect sufficient information to assess and monitor their preparation for AML/CFT and take appropriate measures commensurate with the risks. We do not enter into or maintain correspondent banking arrangements, if the respondent institution is a shell bank or the respondent institution permits their accounts to be used by a shell bank.
9. Training and Education
   We continuously provide all executives and employees with training and education related to AML/CFT to nurture and retain personnel with the expertise and competency required for such roles.
10.  Anti-Bribery and Anti-Corruption
    We make efforts to ensure that all executives and employees have high professional ethics. We prohibit bribes, gifts and entertainment exceeding the extent which is socially considered as acceptable.
11. Evaluation of Effectiveness
    We evaluate the effectiveness of measures related to AML/CFT. We review, improve, and enhance the framework if possibilities of further improvements are identified.
12. Internal Audit
    We periodically conduct internal audits related to AML/CFT framework and make efforts to further improve the framework based on the results of the audits.