Customers Acceptance Policy
Within the scope of the procedures of AML and CTF, JME must develop clear policies and procedures for accepting customers. Customer Acceptance policy lays down the criteria for acceptance of customers like remitter, beneficiaries, correspondent banks. This policy aims to define the set of criteria that will serve as guidelines for JME to accept or refuse a relation with potential customers.
JME in its customer acceptance policy has relevant procedures within the regulatory framework in force and of the best practices, so as to avoid relationship with customers against whom sanctions are applied or those who are facing charges for criminal activity or those who may use the services for “money laundering” or other criminal activity.
JME conducts due diligence of any person applying to do business with it and obtain satisfactory evidence of the identity and legal existence of persons conducting transactions on the basis of reliable documents or other resources and record that identity and other relevant information regarding the customers in their files.
JME does not deal or accept the following person/entities as a customer or partner:
• Anonymous customers
• Illegal immigrants
• Unregistered companies
• Shell banks
• Person/Entities in sanctioned lists issued by the Government of Japan and International bodies such as FATF, UN, US, UK, etc.
If a person/entity refuses to provide the documents proving legal identity viz. identity card, passport, residence card for verification, the relationship shall be refused. This means that JME shall conduct the following:
• Physically inspect the original customer’s identification document (ID) including company registration documents, business license in case of corporate customers and International partners
• Check whether the customer is the person referred to in the identification document
• Take reasonable steps to ensure that the customer’s identification document is genuine esp. in case where customer is not present in person
• Ensure that the records of existing customers remain updated and relevant
• Ensure that the intended transaction meets our AML policy
Potential customers whose acceptance should be refused:
• People whose reputation in the media or in the market are usually associated with criminal activities;
• People whose activity or way of life make it difficult for JME to know the origin of their assets;
• People who do not cooperate with JME by not providing the information required;
• Casinos, entities involved in gambling or betting activities;
• Shell banks;
• Foreign nationals from sanctioned countries viz. Iran, North Korea;
• Politically Exposed Persons (PEPs);
• Customers with suspicious behavior.