What is Money Laundering?

Money laundering refers to the act of concealing illegally obtained money and making it appear that the source of funds is legal. We comply with strict laws and consider it illegal for us or our employees or agents to engage in or attempt to engage in activities that are maliciously or indirectly involved in money laundering. Our anti-money laundering policy improves investor protection, secure payment methods and customer security services.

Anti-Money Laundering Policy

It is important to ensure that our services do not cause inconvenience to customers and are not used for crimes, and to ensure proper operation of funds transfer services in compliance with relevant internal regulations, business rules and regulations.In addition, the company shall prepare a "Specific Business Operator Preparation Document, etc." as a risk assessment for transactions.

1. Compliance with laws and regulations

We comply with Payment Services Act, Criminal Law, Civil Law, Corporate Accounting Principles, Act on Prohibition of Private Monopolization and Maintenance of Fair Trade, Various Administrative Laws, Labor Laws, Act on Prevention of Transfer of Criminal Proceeds, Act on Punishment of Organized Crimes and Control of Proceeds of Crime, Act on the Protection of Personal Information, Foreign Exchange and Foreign Trade Act, and also Act on Submission of Statement of Overseas Wire Transfers for Purpose of Securing Proper Domestic Taxation.

2. Identification and notification of suspicious transactions

To prevent terrorist financing, money laundering, and illegal use of funds transfer services, remittance clients and members must be identified. The Company shall have the person submit the necessary information and confirm whether the notification is correct based on the prescribed identification documents.
Officers and employees shall be discontinued when they receive remittance requests or applications for member registration from customers who cannot identify themselves. In addition, re-identification shall be carried out in the event of a situation requiring identification again.
In addition, if an officer or employee finds a suspicious transaction, the company must report it to the authorities. The business manual illustrates what kind of transaction is suspicious, but if a suspicious transaction is found or cannot be determined, check with the Compliance Manager immediately.

3. Confirmation of legality

According to the Foreign Exchange and Foreign Trade Law, in principle, it is necessary to confirm the following for each remittance.
• Whether the remittance customer or beneficiary does not fall under economic sactions such as asset freeze.
• Whether it violates North Korea's trade-related payment regulations. (Payments made by North Korea as a remittance country, etc.)
• Whether it conflicts with regulations on the use of funds in North Korea and Iran (e.g. activities that may contribute to nuclear-related programs in North Korea and Iran, payments that contribute to Iran's supply of large conventional weapons. Etc.)
Offcers and employees need to check if they fall under the above conditions by system verification and confirm the purpose of remittance.
If this is the case, remittance requests and member regiatration must be declined unless permission issued by the authorities is confirmed.
In addition, it is necessary to check if the remittance customer is applicable to the following:
• Lists of anti-social forces
• Lists of persons subject to economic sanctions such as asset freeze
• PEPs targets (Politically Exposed Persons)
• Lists of OFAC Sanctions (Office of Foreign Assets Control)
• Lists of UN Sanctions

4. Request for submission of notice

For remittance customers other than members, it is necessary to ask the remittance customer to submit a notice and identify them in order to help the tax office understand foreign exchange and other foreign transactions and ofreign assets.

5. Report of scandal

Any fraud, embezzlement, malfeasance, etc. may harm users' interests, such as fraud, embezzlement, breach of trust, etc., or any other act that may interfere with the proper and reliable performance of the business shall be immediately checked with the compliance manager.

6. Examples of Suspicious Transactions (General attention)

The following examples illustrate the types of transactions that should be paid particular attention to when performing the obligation to report suspicious transactions prescribed in Article 9 of the Act on the Prevention of Transfer of Criminal Proceeds.
Therefore, these cases are references to finding or extracting suspicious transactions in the course of daily transactions, and not all formal matches are suspicious transactions, even if they are not, they are subject to notification.

a. Transactions involving customers who provide suspected or unclear information when remittance to a foreign country. In particular, transactions involving customers who provide information about remittance destinations, the purpose of remittance, remittance resources, etc. that are not considered reasonable.
b. Transactions that are frequent in a short period of time with a large amount of money transferred.
c. Transactions involving large remittances for purposes that are not economically rational.
d. Transactions carried out by customers based in countries or regions that are not cooperative in AML measures or in countries or regions that issue illicit drugs. In particular, countries and regions designated by the Financial Services Agency as jurisdictions where surveillance should be strengthened.
e. Transactions made by customers with persons (including corporations) based in countries/regions or countries/regions that are not cooperative in AML measures.
f. Transactions involving customers introduced by persons (including corporations) based in countries/regions or countries/regions that are not cooperative in AML measures.
g. Transactions made in counterfeit currency, counterfeit securities, stolen currency or stolen securities, where the other party to the transaction is suspected of knowing that the currency or securities have been forged or stolen.
h. Transactions involving customers who unnaturally emphasize the confidentiality of transactions and customers who have attempted to request, coerce, acquire, etc. not to make a notification.
i. Transactions involving a member of a crime syndicate, officials of a crime syndicate, etc.
j. Transactions involving customers whose unnatural forms or attitudes, trends, etc. are recognized from the perspective of knowledge, experience, etc.
k. Others (transactions that were inquired or reported as being related to criminal proceeds from outside such as public institutions)