AML/CFT policy.

1. Our obligations

KiShisanMyaku and its execution partners are registered financial-instruments business operators with Japan's FSA and subject to reporting obligations under the Act on Prevention of Transfer of Criminal Proceeds and related FSA guidance.

2. Customer due diligence (CDD)

At account opening we verify for every client:

• Photo government-issued ID, or e-KYC via a Japanese My Number card
• Proof of address (utility bill, bank statement, Juminhyo)
• Occupation and source of funds
• Tax status — My Number and, where applicable, W-8BEN
• Politically-exposed-person (PEP) status
• Sanctions-list screening (UN, OFAC, EU, Japan's MOFA)

3. Ongoing monitoring

Every trade and funding flow is automatically screened against:

• Suspicious activity patterns (structuring, pass-through activity, unnatural asset turnover)
• Sanctions list updates (daily)
• High-risk jurisdiction lists (FATF NCCT)
• Changes to PEP status

4. Reporting

Suspicious transactions are reported to the Japan Financial Intelligence Center (JAFIC) at the FSA, as required under the Act. We are not permitted to notify you of a report except where the law permits.

5. Record retention

We retain KYC, transaction and communication records for seven years after account closure — the requirement under the Act.

6. Training and governance

Every client-facing and operational staff member completes mandatory AML training annually. Our money-laundering-reporting officer (MLRO) reports directly to the board. Our AML framework is reviewed annually by an independent third party.

7. Your cooperation

You agree to cooperate with our AML requirements — including KYC refreshes, source-of-funds queries, and responses to enhanced due-diligence requests within a reasonable period.