The SBI Group, which has a corporate philosophy to “maintain sound ethical values” and “fulfill social responsibility,” believes that it is its core mission to contribute to the maintenance and betterment of society, while fulfilling the demands of its various stakeholders as a constituent member of society.

Recently, as the international restriction on preventing money laundering and financing of terrorism (hereinafter referred to as “ML/FT”) has been strengthened, the SBI Group places this issue as one of its most significant managerial challenge.

Therefore, the Company established a group-wide common policy as stated below, and endeavors to develop, maintain and improve the risk management program based upon the policy. Furthermore, the Company will engage in preventing ML/FT as a group, by encouraging the Group companies to develop risk management programs based on their basic policy in response to the line of business, as well as promoting them to continuously improve the program, and if necessary, urge them to make improvements, through periodic monitoring.

1. Risk management program in preventing ML/FT
The SBI Group endeavors to develop and maintain the risk management program to prevent the misuse of products and services offered by the Group as ML/FT.
2.  Management involvement
As the SBI Group’s managements place anti-money laundering and countering the financing of terrorism measures as a significant challenge in management strategy, it will proactively and aggressively address to this issue.
3.  Identification, assessment and mitigation of risks associated with ML/FT
The SBI Group takes a risk-based approach on identifying ML/FT risks by verifying the risks of the products and services offered, transaction types, the countries and geographic areas of transactions, customer attributes, and other relevant factors. At the same time, the Group assesses the impact of those identified risks on it, and based on the results, will take appropriate measures to mitigate the risks.
4.  Customer due-diligence
The SBI Group strives to eliminate transactions with those on the sanctions list or with inappropriate customers, including antisocial forces, by determining whether or not to accept the customer and by implementing appropriate customer management through procedures for identity verification based on applicable laws and regulations.
5.  Suspicious transaction monitoring and reporting
The SBI Group will implement appropriate monitoring, in order to detect suspicious transactions. In the case of detecting suspicious transactions, it will report to the applicable supervisory authority.
6.  Document and record keeping
Based on applicable laws and regulations, the SBI Group will appropriately keep documents and records relevant to anti-money laundering and countering the financing of terrorism measures.
7.  IT systems and data governance
From the perspective of sophistication and streamlining of anti-money laundering and countering the financing of terrorism measures, the SBI Group will pursue the utilization of IT system and fintech, as well as appropriately manage data.
8.  Continuous improvements
The SBI Group will continuously improve the risk management program on anti-money laundering and countering the financing of terrorism measures through periodical review and internal audit. Also, the SBI Group will develop forward-looking actions for strengthening its anti-money laundering and countering the financing of terrorism measures to prevent the future misuse of the Group’s business.
9.  Training
By proving training opportunities, the SBI Group strives to deepen the knowledge and understanding of its officers and employees within the division associated with the anti-money laundering and countering the financing of terrorism measures, so that they can possess expertise and competency tailored to their roles.

Establishment and revision history:
Established on October 30, 2018