AML/CFT Policy

Fundamental Policy on Measures Against Money Laundering and Terrorist Financing Interbank HD Co., Ltd.

Interbank HD Co., Ltd. and each of its group companies (hereinafter collectively referred to as “the Company”) operates under the founding business philosophy of “supporting regional foreign currency exchange infrastructure,” and contributes to the improved convenience of inbound foreign visitors and the revitalisation of regional economies through the development, manufacture, and sale of foreign currency exchange machines (hereinafter referred to as “exchange machines”) and the operation of foreign currency exchange services.

As a company engaged in this business, the Company hereby establishes this Fundamental Policy on Measures Against Money Laundering and Terrorist Financing (hereinafter referred to as “money laundering and terrorist financing” or “ML/TF”) and commits to the prevention of money laundering and terrorist financing.

Fundamental Policy

[Management Policy] The Company positions the prevention of ML/TF as a critical management priority and commits to addressing it proactively and actively under the leadership of senior management.
[Framework Development and Training] In order to address the prevention of ML/TF, the Company will establish the necessary organisational framework, conduct training for officers and employees to deepen their knowledge and understanding, and endeavour to maintain that knowledge and understanding. The Company will also appropriately communicate the applicable response standards to facilities at which exchange machines are installed (including accommodation facilities, tourist facilities, and similar establishments).
[Risk Identification, Assessment, and Mitigation] The Company will identify and assess risks relating to ML/TF and will implement risk mitigation measures commensurate with those risks. Risk assessments will be conducted taking into account the characteristics of transaction patterns at foreign currency exchange machines, including transaction amounts, currency types, and frequency of use.
[Customer Identification and Exclusion of Anti-Social Forces] The Company will endeavour to exclude anti-social forces and mitigate the risk of sanctions violations by implementing customer identification procedures in accordance with the Act on Prevention of Transfer of Criminal Proceeds (the “APTCP”), as well as other relevant laws and regulations including the Foreign Exchange and Foreign Trade Act and the Payment Services Act.
[Detection and Reporting of Suspicious Transactions] The Company will conduct monitoring based on its risk assessment in order to detect suspicious transactions in a timely manner, and where such transactions are detected, will promptly file a report with the relevant supervisory authorities (including the Finance Bureau and the National Police Agency). The Company will also work to establish an automated detection framework utilising system logs and transaction data from exchange machines.
[Record Retention] The Company will appropriately retain transaction records, customer identification records, and other records relating to ML/TF in accordance with applicable laws and regulations.
[Internal Audit and Continuous Improvement] The Company will conduct internal audits to regularly verify its ML/TF prevention measures, and will endeavour to verify their effectiveness and achieve continuous improvement.
[Management of Sales Partners and Installation Facilities] The Company will provide necessary information and guidance to ensure that sales partners and installation facilities for exchange machines are able to implement appropriate AML/CFT measures. The Company will also require compliance with applicable laws and regulations across its entire supply chain, including manufacturing contractors, and will endeavour to establish a cooperative framework.

Established: 1 April 2024 Last revised: 14 November 2025

Interbank HD Co., Ltd. Representative Director: Go Sato