Effective Date: Immediately
Last Updated: November 10, 2024
1. Purpose and Commitment
Banfield Capital (“we,” “our,” or “the Firm”) is firmly committed to conducting business with integrity and in full compliance with all applicable laws and regulations designed to prevent money laundering, terrorist financing, and other forms of financial crime.
We uphold the principles established under the Act on Prevention of Transfer of Criminal Proceeds (Japan), as well as the recommendations of the Financial Action Task Force (FATF) and other international standards. Our policy is designed to safeguard our operations, clients, and partners from being used for illicit financial activity.
2. Scope of This Policy
This policy applies to:
- All Banfield Capital employees, officers, and directors;
- Any subsidiaries, affiliates, and third-party service providers engaged in our operations; and
- All clients and counterparties with whom Banfield Capital conducts business.
3. Objectives
The objectives of this AML Policy are to:
- Prevent Banfield Capital from being used as a vehicle for money laundering or terrorist financing;
- Ensure compliance with all applicable AML/CFT (Anti–Money Laundering / Counter–Financing of Terrorism) regulations;
- Detect and report suspicious transactions in a timely manner; and
- Promote a culture of ethical conduct, transparency, and regulatory compliance.
4. Client Due Diligence (CDD)
Before establishing any client relationship, Banfield Capital performs thorough Know Your Customer (KYC) and Client Due Diligence (CDD) procedures. This process includes:
- Verification of the client’s identity using reliable, independent documentation (such as passports or corporate registration documents);
- Understanding the nature and purpose of the client’s relationship with the Firm;
- Assessing the source of funds and wealth; and
- Ongoing monitoring to ensure the information remains accurate and up to date.
For high-risk clients or jurisdictions, Enhanced Due Diligence (EDD) is performed, which may involve additional verification and approval procedures.
5. Monitoring and Reporting
Banfield Capital continuously monitors transactions and account activity to identify unusual or suspicious behavior.
Where suspicious activity is detected, we will:
- Conduct an internal review; and
- Report the matter promptly to the Japan Financial Intelligence Center (JAFIC) or other competent authorities, as required by law.
All employees are required to report any suspicious activity or concern to the designated Compliance Officer without delay.
6. Record Keeping
The Firm maintains detailed records of all client identification data, account files, and transaction histories for at least seven (7) years from the date of the transaction or termination of the business relationship, whichever is later.
These records are securely stored and may be made available to regulatory or law enforcement authorities upon lawful request.
7. Training and Awareness
Banfield Capital provides regular AML/CFT training to all relevant employees to ensure awareness of:
- Applicable laws and regulatory obligations;
- The identification and reporting of suspicious transactions; and
- The importance of compliance in protecting both the Firm and its clients.
Participation in AML/CFT training is mandatory for all employees and forms part of our ongoing compliance culture.
8. Risk-Based Approach
Banfield Capital adopts a risk-based approach (RBA) to AML/CFT compliance. This means that the level of due diligence, monitoring, and review applied to each client or transaction is commensurate with its assessed risk level.
Factors considered in assessing risk include:
- Geographic location and jurisdiction of the client;
- Nature of the client’s business or source of funds;
- Type and complexity of the financial products involved; and
- Any adverse media or regulatory history associated with the client.
9. Sanctions Compliance
Banfield Capital complies fully with all applicable United Nations, Japanese, U.S., U.K., and EU sanctions regimes. The Firm will not enter into or maintain relationships with individuals or entities subject to international sanctions or located in jurisdictions that present unmanageable AML/CFT risks.
10. Governance and Oversight
Overall responsibility for AML compliance rests with Banfield Capital’s Board of Directors, which ensures that effective policies, controls, and procedures are maintained. The Firm’s designated AML Compliance Officer oversees daily implementation, monitoring, and reporting obligations.
11. Review and Updates
This AML Policy is reviewed at least annually or as needed to reflect changes in legal or regulatory requirements, industry standards, or the Firm’s operational structure. Any amendments will be approved by senior management and communicated to all staff.
12. Contact
Questions or concerns regarding this policy may be directed to:
Compliance Department
Banfield Capital
Tokyo, Japan