Our Basic Policy Regarding Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT)
As a financial institution, Merpay, Inc. strongly recognizes the importance of our public mission. We also recognize that some of the most important factors for conducting sound business operations include actively rejecting all relationships with anti-social forces and developing a system against money laundering. As such, Mercari Group has implemented the following risk management system in order to observe the related laws and ordinances.
Leadership by Upper Management
Merpay, Inc. will appoint an officer responsible for AML/CFT and give them the authority and information necessary to carry out the role. In addition, upper management will take the lead in AML/CFT matters.
Risk-Based Approach
The team in charge of AML/CFT will develop the necessary policies, procedures, and plans so that all employees of Merpay, Inc. can take a unified, organizational approach to AML/CFT. In addition, we will assess the risk of money laundering, etc., on a regular and as-necessary basis, and will develop and improve the management system commensurate to the assessed risk.
The Three-Line Structure
In order to develop an effective AML/CFT framework, Merpay, Inc. will clarify the roles and responsibilities of each team, and conduct management control through three lines of defense, including an internal audit function that provides an independent opinion.
Training & Education
The team in charge of AML/CFT will provide training and education to ensure that officers and employees fully understand any relevant AML/CFT policies, procedures, plans, etc., and accurately implement mitigation measures commensurate with the assessed risk.
Cooperation with the Regulatory Authorities & Law Enforcement
Merpay, Inc. will work closely and cooperate with relevant ministries and agencies, by sharing information to contribute to the prevention, detection, and management of money laundering, etc. Should a transaction suspected of money laundering, etc. be discovered, we will promptly notify the authorities.