Liberty Exchange JAPAN Co., Ltd. (hereinafter referred to as "our company") recognizes the importance of preventing money laundering and the financing of terrorism (hereinafter referred to as "money laundering, etc.") in light of stringent regulations on these matters. As such, we have established this Basic Policy on the Prevention of Money Laundering (hereinafter referred to as "this policy").

Organizational Structure

Our company will establish an internal structure to prevent our products and services from being exploited for money laundering, etc.

Customer Management

In accordance with laws against the proceeds of crime and other relevant legislation, our company will verify and document various customer-related details such as occupation, business activities, background, source of funds, assets, income, country of residence, and address. This information will be leveraged effectively to prevent money laundering, etc. We will also develop record-keeping policies that align with applicable laws and regulations.

Confirmation of Asset Freezing Measures

Our company will develop an internal structure to ensure the confirmation of measures such as asset freezing against terrorists and the like. We will also strive to enhance awareness about preventing money laundering, etc., to enable the execution of appropriate measures.

Reporting of Suspicious Transactions

Our company will formulate procedures for reporting suspicious transactions. We will promptly report to the regulatory authorities and appropriately manage any suspicious transactions detected through monitoring our customer transactions, in line with laws and regulations.

Staff Training

Our company will regularly conduct training related to the prevention of money laundering, etc., and strive to improve the knowledge and awareness of our officers and employees.

Internal Audits

Our company will periodically conduct internal audits on the compliance status of measures to prevent money laundering, etc., and strive to improve the internal structure based on the audit results.