Anti–Money Laundering (AML) Policy
Effective Date: Immediately
Last Updated: May 28, 2024
Gifford Roth (“we,” “our,” “us”) is committed to the highest standards of anti–money laundering (AML) compliance and counter–terrorist financing (CTF). We fully support global efforts to prevent the misuse of the financial system and to detect, deter, and report suspicious activities.
1. Purpose and Scope
This policy outlines our approach to preventing and detecting money laundering and the financing of terrorism. It applies to all employees, contractors, and associated persons of Gifford Roth, as well as any parties engaged in business with us.
2. Regulatory Compliance
- The Financial Services Agency (Japan) requirements
- The Financial Action Task Force (FATF) recommendations
- Relevant AML regulations in other applicable jurisdictions where we serve clients
3. Know Your Customer (KYC) and Client Due Diligence (CDD)
We maintain a rigorous KYC process to verify the identity of all clients prior to establishing a business relationship. This includes:
- Verification of personal identification documents (e.g., passport, government-issued ID)
- Verification of corporate entities and beneficial ownership structures
- Assessment of the nature, purpose, and intended activity of the relationship
- Ongoing monitoring to ensure client information is accurate and up to date
Enhanced due diligence (EDD) is applied where higher risk factors are identified, such as politically exposed persons (PEPs) or clients from high-risk jurisdictions.
4. Risk-Based Approach
Our AML program is designed around a risk-based approach. We assess the risk profile of each client and transaction, taking into account geographic location, type of service requested, transaction patterns, and other relevant indicators. This allows us to focus resources where risks are highest.
5. Monitoring and Reporting
We employ continuous monitoring of client activity to detect unusual or suspicious transactions. This includes:
- Automated and manual transaction monitoring
- Investigation of anomalies or inconsistencies
- Filing suspicious transaction reports (STRs) with relevant authorities as required by law
6. Record Keeping
In compliance with legal requirements, we maintain detailed records of client identification documents, transaction history, and any related communications for the prescribed statutory period, even after the client relationship ends.
7. Training and Awareness
All employees receive regular AML training to ensure they:
- Understand the legal and regulatory requirements
- Can identify and escalate suspicious activity
- Are aware of internal reporting channels and procedures
8. Cooperation with Authorities
Gifford Roth fully cooperates with law enforcement and regulatory agencies in their efforts to investigate and prevent money laundering and terrorist financing activities.
9. Policy Review
This AML Policy is reviewed annually, or more frequently if required by regulatory changes, to ensure it remains effective and compliant with all applicable laws and standards.
10. Contact for AML Matters
For questions or concerns regarding this AML Policy, or to report suspicious activity, please contact our Compliance Department:
Gifford Roth – Compliance Department
Address: Tokyo, Japan
Email: info@giffordroth.com