At Alfa Marushima Co., Ltd. (“Company,” “we,” “our,” or “us”), we are fully committed to preventing money laundering, terrorist financing, and other forms of financial crime. This Anti-Money Laundering (AML) Policy outlines our adherence to applicable laws and regulations in the jurisdictions where we operate, as well as international AML standards.
Purpose
The purpose of this AML Policy is to:
- Prevent the misuse of Alfa Marushima’s services for money laundering or terrorist financing.
- Comply with all applicable AML laws, regulations, and guidelines in the regions where we operate.
- Protect the integrity of the financial system and our reputation as a responsible financial services provider.
What Is Money Laundering?
Money laundering involves the process of disguising the proceeds of criminal activities to make them appear legitimate. This process generally includes three stages:
- Placement: Introducing illicit funds into the financial system.
- Layering: Concealing the origin of funds through complex transactions.
- Integration: Reintroducing the funds into the legitimate economy.
Terrorist financing refers to providing funds to support terrorist activities, often using methods similar to money laundering.
Our Commitments
Alfa Marushima is committed to:
- Compliance: Fully adhering to AML laws and regulations in all jurisdictions in which we operate.
- Risk Management: Identifying, assessing, and mitigating AML risks.
- Customer Due Diligence (CDD): Implementing thorough Know Your Customer (KYC) procedures.
- Training and Awareness: Ensuring employees are trained on AML policies, procedures, and red flags.
- Reporting: Reporting suspicious activities to the relevant authorities in a timely and accurate manner.
Customer Due Diligence (CDD)
We conduct CDD to verify the identity and legitimacy of our clients. This includes:
Identification
- Collecting and verifying personal information, such as name, date of birth, address, and government-issued identification.
- For entities, verifying corporate documentation, ownership structure, and authorized representatives.
Risk-Based Approach
- Assessing clients based on their risk profile, considering factors such as geographical location, nature of business, and transaction patterns.
- Applying enhanced due diligence (EDD) for higher-risk clients or transactions.
Ongoing Monitoring
- Regularly reviewing customer information and transaction activity to detect and address anomalies.
- Updating KYC records as necessary.
Suspicious Transaction Reporting
We are obligated to monitor, detect, and report any suspicious transactions or activities to the relevant authorities. This includes:
- Transactions that appear inconsistent with a client’s known profile or legitimate business activities.
- Unusually complex or large transactions without a clear economic purpose.
- Transfers to or from jurisdictions identified as high risk by international regulatory bodies.
Prohibited Activities
We strictly prohibit the following activities:
- Assisting clients in concealing the origins of illicit funds.
- Establishing business relationships with individuals, entities, or jurisdictions subject to sanctions or identified as high-risk.
- Facilitating transactions that violate applicable laws or international AML standards.
Employee Training and Responsibility
All Alfa Marushima employees are required to:
- Participate in regular AML training programs to understand their roles in preventing financial crime.
- Recognize and report potential red flags for money laundering or terrorist financing.
- Adhere to the Company’s AML policies and procedures at all times.
Record Retention
We maintain records of customer information, transactions, and reports in accordance with legal requirements, ensuring they are securely stored and readily accessible for audits
or investigations.
International Standards
We align our AML practices with global standards, including those established by international organizations such as the Financial Action Task Force (FATF) and other recognized regulatory frameworks.
At Alfa Marushima Co., Ltd. (“Company,” “we,” “our,” or “us”), we are fully committed to preventing money laundering, terrorist financing, and other forms of financial crime. This Anti-Money Laundering (AML) Policy outlines our adherence to applicable laws and regulations in the jurisdictions where we operate, as well as international AML standards.
Policy Review and Updates
We regularly review and update this AML Policy to ensure it remains effective and compliant with evolving laws and regulations.
Contact Us
For questions or concerns about this AML Policy, please contact us:
Info@alfamarushima.com
By adhering to this AML Policy, Alfa Marushima Co., Ltd. aims to uphold the highest standards of integrity and contribute to the global effort to combat financial crime. Thank you for your cooperation.