Anti-Money Laundering Policy
Introduction
S&H Management (“we,” “our,” or “us”) is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. This Anti-Money Laundering (AML) Policy outlines our approach to preventing, detecting, and reporting money laundering, terrorist financing, and other financial crimes.
Money laundering and related activities undermine the integrity of the financial system. S&H Management takes its responsibilities seriously and applies a risk-based approach consistent with applicable laws and regulations in Japan, as well as relevant international standards.
Purpose and Scope
The purpose of this AML Policy is to:
- Prevent the use of S&H Management’s services for money laundering or terrorist financing
- Establish clear principles for client due diligence and ongoing monitoring
- Ensure compliance with applicable AML and counter-terrorist financing (CTF) laws and regulations
- Protect clients, employees, and the firm from legal, reputational, and operational risk
This policy applies to all employees, officers, and representatives of S&H Management and covers all business relationships and activities.
Regulatory Framework
S&H Management operates within the framework of Japan’s AML and CTF regulations and aligns its practices with internationally recognized standards, including those promoted by the Financial Action Task Force (FATF).
Where clients, assets, or activities involve multiple jurisdictions, we take reasonable steps to ensure compliance with applicable cross-border AML requirements.
Risk-Based Approach
S&H Management applies a risk-based approach to AML compliance. This involves assessing and managing risks based on factors such as:
- Client type and profile
- Geographic exposure
- Nature and complexity of services provided
- Transaction characteristics
Enhanced measures may be applied where higher risk is identified, while simplified measures may be used where permitted for lower-risk situations.
Client Due Diligence (CDD)
We conduct appropriate client due diligence before establishing a business relationship and on an ongoing basis thereafter. CDD measures may include:
- Identifying and verifying client identity using reliable, independent sources
- Understanding the nature and purpose of the business relationship
- Identifying beneficial owners where applicable
- Assessing the source of funds and, where appropriate, source of wealth
Where required, enhanced due diligence (EDD) is applied, particularly for higher-risk clients or situations.
Ongoing Monitoring
S&H Management monitors client relationships and activities on an ongoing basis to ensure consistency with the client’s profile, stated objectives, and risk assessment. Monitoring may include:
- Periodic review of client information and documentation
- Review of transactions and account activity, where applicable
- Updating risk assessments as circumstances change
Unusual or suspicious activity is reviewed promptly and escalated in accordance with internal procedures.
Politically Exposed Persons (PEPs)
We apply enhanced scrutiny to relationships involving Politically Exposed Persons (PEPs), their family members, or close associates, in accordance with applicable regulations. Additional due diligence and senior management approval may be required before establishing or continuing such relationships.
Reporting of Suspicious Activity
Where required by law, S&H Management reports suspicious transactions or activities to the relevant authorities. Employees are required to escalate concerns internally in a timely manner and must not disclose (“tip off”) clients or third parties about any such reports.
Record Keeping
We maintain appropriate records relating to client identification, due diligence, and transactions for the period required by applicable laws and regulations. Records are stored securely and made available to authorities when lawfully requested.
Employee Training and Awareness
S&H Management provides ongoing AML training to ensure that employees understand their responsibilities, recognize potential indicators of money laundering or terrorist financing, and comply with internal policies and procedures.
Data Protection and Confidentiality
All information collected for AML purposes is handled in accordance with applicable data protection and privacy laws. Access to such information is restricted to authorized personnel and used solely for compliance and regulatory purposes.
Governance and Oversight
Senior management is responsible for overseeing the implementation and effectiveness of this AML Policy. The policy is reviewed periodically and updated as necessary to reflect changes in laws, regulations, or business activities.
Breaches and Non-Compliance
Failure to comply with this AML Policy may result in disciplinary action and, where appropriate, reporting to regulatory or law enforcement authorities.
Changes to This Policy
S&H Management reserves the right to amend this AML Policy at any time to ensure ongoing compliance with regulatory requirements and best practices. Updates will be made available as appropriate.
Contact Information
If you have questions regarding this AML Policy or our compliance practices, please contact S&H Management using the contact details provided on this website.
Last updated: August 2025