Global Financial Crimes Policy Statement
Financial Crimes Risk Management Overview
- MUFG Bank, Ltd.; Mitsubishi UFJ Trust and Banking Corporation; Mitsubishi UFJ Securities Holdings Co., Ltd.; Mitsubishi UFJ NICOS Co., Ltd.; and ACOM CO., LTD.
MUFG's Approach to Financial Crimes Risk Management
MUFG established the Global Financial Crimes Division ("GFCD”) to define and oversee the implementation of consistent financial crimes risk management controls Group-wide. Each Subsidiary has established Compliance Divisions responsible for managing their respective financial crimes compliance programs under the oversight of their Boards of Directors, who have ultimate responsibility for the overall control framework.
Led by financial crimes compliance specialists, GFCD and the Subsidiary Compliance Divisions address the three financial crimes risk areas – Anti-Money Laundering ("AML")/Countering the Financing of Terrorism (“CFT"), Sanctions, and Anti-Bribery and Corruption ("ABC"). The Policy Statements for each of the three financial crimes risk areas are below.
AML/CFT Policy Statement
MUFG and its Subsidiaries are committed to complying with both the letter and spirit of applicable AML/CFT laws everywhere we do business. This commitment includes zero tolerance for known acts of money laundering and terrorist financing.
Specifically, the MUFG AML/CFT Policy, which is made available to all employees in the form of Subsidiary-level AML policies, prohibits:
- Knowingly facilitating or participating in any financial crimes activity or any activity that facilitates financial crimes (e.g., money laundering and financing of criminal activities);
- Ignoring information or circumstances that may be indicative of financial crimes;
- Informing any person known to be involved or suspected of being involved in illegal or suspicious activity that such activity is being investigated or reported internally and/or to law enforcement authorities and regulatory agencies (known as “tipping off”);
- Allowing a new customer to transact prior to completion of the know-your-customer (“KYC”) process;(note) or
- Onboarding a prohibited customer type, without appropriate exception or exemption.
- MUFG Subsidiaries may permit a potential customer to execute transactions before completing the customer verification process where doing so is essential to avoid interruptions to the normal conduct of business and does not conflict with local law. In limited circumstances, a Subsidiary may permit a temporary extension to complete the KYC process or an exemption/exception from a particular KYC requirement.
- Designated persons responsible for their Subsidiaries’ AML/CFT compliance programs, including, as appropriate, dedicated AML/CFT officers in each country of operation;
- Annual AML/CFT risk assessments;
- KYC processes that require identification and appropriate verification of customer identities (including identification of ultimate beneficial owners), customer screening, customer due diligence, enhanced due diligence, customer acceptance/rejection, and customer reviews;
- Transaction monitoring systems and processes designed to detect unusual and potentially suspicious activity;
- Investigation processes to identify and report suspicious activity in compliance with applicable regulatory requirements;
- Prohibitions on relationships with certain customer types, including a prohibition on relationships with shell banks;
- AML/CFT information-sharing and record keeping processes; and
- Periodic employee training on applicable AML/CFT risks and controls (e.g., policy and procedure requirements).
Sanctions Policy Statement
MUFG and its Subsidiaries are committed to complying with both the letter and spirit of applicable economic sanctions laws everywhere we do business. This commitment includes zero tolerance for acts of sanctions circumvention and evasion.
The MUFG Sanctions Policy, which is made available to all employees in the form of Subsidiary-level sanctions policies, prohibits the funding of accounts and the processing of payments for, on behalf of, or for the benefit of, sanctions targets or jurisdictions in violation of applicable sanctions, including those established by U.S. Department of the Treasury’s Office of Foreign Assets Control and the Ministry of Finance in Japan.
Consistent with the MUFG Sanctions Policy, the Subsidiaries have established sanctions compliance programs, including the following control processes to the extent applicable:
- Sanctions screening and reviews with respect to customer on-boarding and processing of transactions;
- Annual assessments of sanctions risks and controls; and
- Periodic employee training on applicable sanctions risks and controls (e.g., policy and procedure requirements).
ABC Policy Statement
MUFG and its Subsidiaries are committed to fostering a corporate culture of ethical business practices and compliance with both the letter and spirit of the law everywhere we do business. This commitment includes zero tolerance for acts of bribery and corruption.
The MUFG ABC Policy, which is made available to all employees in the form of Subsidiary-level ABC policies, comprehensively addresses the key concepts of bribery and corruption and prohibits offering, giving, soliciting, or receiving, directly or indirectly, anything of value to or from anyone in exchange for an improper business benefit or advantage. The Policy also prohibits facilitation payments and falsifying books, records, and accounts relating to Subsidiaries’ business activities.
Consistent with the MUFG ABC Policy, the Subsidiaries have established ABC compliance programs including the following control processes, which comprehensively address bribery and corruption:
- Annual assessment of bribery and corruption risks and controls;
- Risk-based due diligence and oversight of third-party service providers who act on a Subsidiary's behalf (i.e., intermediaries);
- Review of gifts and hospitality, offers of employment/work experience, and charitable donations, particularly activities involving public officials;
- Evaluation and management of risks associated with business transactions, including mergers and acquisitions; and
- Periodic employee training on applicable bribery and corruption risks and controls (e.g., a review of key concepts of bribery and corruption, including different elements/types, and policy and procedure requirements).
Additional Program Elements
(As of July 2022)