Last updated: October 17, 2025
Affluence Management (“Affluence Management,” “we,” “us,” or “our”) is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering Policy (the “Policy”) outlines the principles, controls, and procedures adopted by Affluence Management to comply with applicable laws and regulations in Japan, including the Act on Prevention of Transfer of Criminal Proceeds and related guidelines.
This Policy applies to Affluence Management, its officers, employees, and, where applicable, contractors and representatives.
1. Policy Objectives
- Prevent the use of Affluence Management’s services for money laundering or terrorist financing
- Establish a robust framework for customer due diligence and ongoing monitoring
- Ensure compliance with applicable Japanese laws, regulations, and regulatory guidance
- Protect the integrity, reputation, and operations of Affluence Management
2. Legal and Regulatory Framework
Affluence Management operates in accordance with applicable anti-money laundering and counter-terrorist financing (“AML/CFT”) laws and regulations, including but not limited to:
- Act on Prevention of Transfer of Criminal Proceeds (Japan)
- Relevant Cabinet Orders and Ordinances
- Guidelines issued by the Financial Services Agency of Japan (FSA)
Where appropriate, Affluence Management also takes into account international standards, including recommendations issued by the Financial Action Task Force (FATF).
3. Risk-Based Approach
Affluence Management adopts a risk-based approach to AML/CFT. This involves identifying, assessing, and managing money laundering and terrorist financing risks associated with:
- Clients and beneficial owners
- Products and services
- Transactions and delivery channels
- Geographic exposure
The level of due diligence and monitoring applied will be proportionate to the assessed level of risk.
4. Customer Due Diligence (CDD)
Affluence Management conducts customer due diligence prior to establishing a business relationship and, where appropriate, on an ongoing basis.
CDD measures may include:
- Identification and verification of the client’s identity using reliable, independent source documents
- Identification and verification of beneficial owners, where applicable
- Understanding the purpose and intended nature of the business relationship
- Obtaining information on the source of funds and, where appropriate, source of wealth
Affluence Management will not establish or continue a business relationship where required CDD cannot be satisfactorily completed.
5. Enhanced Due Diligence (EDD)
Enhanced due diligence is applied to higher-risk situations, including but not limited to:
- Politically exposed persons (PEPs) and their close associates or family members
- Clients or transactions involving high-risk jurisdictions
- Unusual or complex ownership structures
EDD measures may include obtaining additional information, senior management approval, and enhanced ongoing monitoring.
6. Ongoing Monitoring
Affluence Management monitors client relationships and transactions on an ongoing basis to ensure that activity is consistent with the client’s profile, business, and risk assessment.
Ongoing monitoring includes:
- Reviewing transactions for unusual or suspicious activity
- Keeping client information and documentation up to date
- Reassessing client risk levels periodically or upon trigger events
7. Suspicious Transaction Reporting
Where Affluence Management knows, suspects, or has reasonable grounds to suspect that funds are the proceeds of criminal activity or related to terrorist financing, a suspicious transaction report (STR) will be filed with the relevant authorities in accordance with applicable laws.
Employees are required to promptly escalate any suspicious activity internally in accordance with established procedures.
8. Record Keeping
Affluence Management maintains records of customer identification, due diligence information, transaction records, and STR-related documentation for the period required under applicable law.
Records are maintained in a manner that allows for timely retrieval and inspection by competent authorities.
9. Training and Awareness
Affluence Management provides AML/CFT training to relevant employees to ensure they understand:
- Applicable AML/CFT obligations
- How to identify and report suspicious activity
- Their responsibilities under this Policy
Training is conducted on a periodic basis and updated as necessary to reflect regulatory changes.
10. Governance and Responsibility
Overall responsibility for AML/CFT compliance rests with senior management.
Affluence Management designates an appropriate individual or function responsible for overseeing the implementation and effectiveness of this Policy, including monitoring compliance and reporting to senior management.
11. Confidentiality
All information related to AML/CFT reviews, investigations, and suspicious transaction reports is handled confidentially and disclosed only as permitted or required by law.
12. Review and Updates
This Policy is reviewed periodically and updated as necessary to reflect changes in laws, regulations, regulatory expectations, or business activities.
13. Contact Information
For questions regarding this Policy, please contact:
Affluence Management
Tokyo, Japan
Email: info@affluence-mgt.com