Introduction

Tokyo Asset Management ("TAM") is committed to maintaining the highest standards of compliance with international Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. This policy outlines TAM's comprehensive framework to prevent, identify, and mitigate risks associated with money laundering, terrorist financing, and other illicit activities. By adhering to applicable laws and leveraging advanced compliance technologies, TAM ensures the integrity of its financial operations and services across all jurisdictions.

This AML Policy serves as a cornerstone of our commitment to ethical and lawful business practices, embodying internationally recognized standards such as the FATF Recommendations, EU Directives, and United Nations conventions. Through a robust risk-based approach, we strive to safeguard our platform and clients against financial crimes while preserving trust in global financial systems.

Money Laundering

Definition:
Money laundering involves processing criminally derived funds to disguise their illicit origin and integrate them into the legal financial system. TAM recognizes the complexity of money laundering activities, which often span the following stages:

1. Placement: Introduction of illicit funds into the financial system through deposits, transfers, or other mechanisms.
2. Layering: Obfuscating the trail of illegal funds by conducting complex financial transactions to disconnect the money from its criminal origin.
3. Integration: Reintroducing laundered funds into the economy by presenting them as legitimate assets through investments or legal acquisitions.

TAM adopts a zero-tolerance policy towards all forms of money laundering. Independent of predicate offenses, the act of concealing the origins of criminally derived funds is treated as a distinct crime and will be reported to relevant authorities.

Prohibited Actions:
TAM expressly prohibits:

• Any transaction or activity involving assets suspected of being derived from criminal conduct.
• Concealing or disguising the origin, source, or ownership of illegally acquired property.
• Engaging in any preparatory, complicit, or intentional actions that facilitate money laundering.

Terrorist Financing

Definition:
Terrorist financing involves the provision or collection of funds, directly or indirectly, with the intention or knowledge that they will be used to support terrorist acts, organizations, or activities. Unlike money laundering, such funds may originate from both legal and illegal sources.

TAM strictly prohibits engaging with entities or individuals designated as terrorists or associated with terrorism. Through stringent screening measures, TAM ensures that its platform is not exploited for purposes of terrorist financing.

Tax Evasion and Fraud

Tax evasion involves the deliberate attempt to evade tax liabilities through illegal practices, such as misrepresentation, omission, or fraud. TAM is committed to preventing its platform from being used to facilitate:

• Falsification or concealment of taxable income.
• Manipulation of financial insolvency to evade taxes.
• Misuse of corporate structures to obscure financial responsibilities.

By enforcing robust due diligence procedures, TAM ensures compliance with international tax transparency standards.

Bribery and Corruption

Bribery and corruption undermine the integrity of financial systems. TAM takes a proactive stance to prevent:

• The offering or receiving of undue advantages to influence business decisions or public duties.
• Any activity that facilitates the concealment of illicit funds through corrupt practices.

Our anti-corruption measures are aligned with global frameworks such as the OECD Anti-Bribery Convention and UN Anti-Corruption Initiatives.

Risk-Based Approach

TAM employs a Risk-Based Approach (RBA) to assess and mitigate risks associated with money laundering and terrorist financing. Key components include:

• Risk Identification: Evaluating potential risks based on user profiles, transactional behavior, and geographic considerations.
• Risk Assessment: Assigning risk ratings to users, transactions, and business activities to prioritize monitoring efforts.
• Risk Mitigation: Implementing tailored controls, including transaction thresholds, enhanced due diligence, and automated monitoring systems, to address identified risks effectively.

Customer Due Diligence (CDD)

TAM's CDD framework is integral to preventing financial crimes. CDD measures include:

• Verifying user identities through reliable and independent documentation.
• Assessing the purpose and intended nature of business relationships.
• Ongoing monitoring of user activities and updating user information as needed.

For higher-risk users, Enhanced Due Diligence (EDD) measures are applied, including deeper identity verification, transaction analysis, and scrutiny of associated accounts or wallets.

Sanctions Compliance

TAM enforces strict compliance with international sanctions regimes, including but not limited to:

• United Nations Security Council Sanctions.
• EU Consolidated Sanctions List.
• U.S. Office of Foreign Assets Control (OFAC) List.

All users are screened against these lists, and any matches are reported to the appropriate regulatory authorities.

Transaction Monitoring

TAM utilizes advanced technologies for real-time transaction monitoring, including:

• Automated fraud detection systems to flag suspicious activity.
• Comprehensive analysis of transactional patterns, IP addresses, and cryptocurrency wallet behaviors.
• Reporting of any anomalies or suspicious transactions to designated authorities through Suspicious Activity Reports (SARs).

Internal Controls and Training

TAM ensures the effectiveness of its AML policy through:

• Regular audits and reviews of AML processes and systems.
• Mandatory training for employees on AML/CTF laws, emerging threats, and internal reporting procedures.
• Implementation of governance structures to oversee AML compliance, including the appointment of a dedicated AML Compliance Officer.

Regulatory Compliance

TAM adheres to international AML/CTF standards, including:

• Financial Action Task Force (FATF) Recommendations.
• EU Anti-Money Laundering Directives (4th, 5th, and 6th).
• Domestic AML laws in jurisdictions where TAM operates, ensuring full compliance with local regulations.

TAM also cooperates with global authorities such as FINTRAC, AUSTRAC, NCA, and others to maintain the integrity of its operations.

Amendments and Final Provisions

This AML Policy is subject to periodic updates to reflect changes in legislation or business practices. Users are encouraged to review the policy regularly. By using TAM’s services, users acknowledge their acceptance of this policy and agree to comply with its terms.

For inquiries regarding this AML Policy, please contact:
Tokyo Asset Management AML Compliance Department
[Insert Email]

This policy is effective as of the date listed above. TAM reserves the right to amend or modify this policy at its sole discretion.