AML Policy

This agreement between Opera Payments Limited (hereinafter referred to as “the Company” or “Opera”) and the customer, including where applicable access to and use of this website (hereinafter referred to as “the Site”), and the services provided by Opera to the customer (hereinafter collectively referred to as “the Services”), recognizes the importance of Anti-Money Laundering, Counter-Terrorism Financing, and Counter-Proliferation Financing (*2) (hereinafter collectively referred to as Anti-Money Laundering, etc.), as well as compliance with Foreign Exchange and Foreign Trade Laws (*3), and establishes the following policy.

1. Organizational Structure and Management Policy

The Opera Group positions Anti-Money Laundering, etc. and compliance with Foreign Exchange and Foreign Trade Laws as top management priorities. Under the proactive involvement of management, the Group establishes organizational structures for Anti-Money Laundering, etc. and compliance, clarifies the roles of responsible persons and staff, and ensures cooperation among related departments for information gathering and appropriate responses.

2. Risk-Based Approach

In relation to Anti-Money Laundering, etc. and compliance with Foreign Exchange and Foreign Trade Laws, the Opera Group adopts a risk-based approach, identifying and assessing risks in a timely and appropriate manner, and implementing mitigation measures proportionate to those risks.

3. Customer Due Diligence

The Opera Group conducts appropriate investigations and verification of customer information and transaction details based on relevant laws and regulations, and implements ongoing customer due diligence.

4. Reporting of Suspicious Transactions

The Opera Group promptly reports detected suspicious transactions to the relevant authorities as “Suspicious Transaction Reports.”

5. Management of Correspondent Relationships

The Opera Group endeavors to collect sufficient information on correspondent institutions and implements Anti-Money Laundering, etc. and compliance measures regularly or as necessary.

6. Training for Officers and Employees

The Opera Group continuously provides training on Anti-Money Laundering, etc. and compliance with Foreign Exchange and Foreign Trade Laws, to enhance the knowledge and awareness of officers and employees.

7. Audit of Compliance Status

The Opera Group conducts periodic audits by independent auditors on the effectiveness of measures related to Anti-Money Laundering, etc. and compliance, and makes continuous efforts to improve these measures based on the audit results.

*1 Group companies covered by this policy

*2 Money Laundering refers to “the act of concealing the origin of criminal proceeds to disguise them as legitimate funds,” Terrorist Financing refers to “the act of providing funds necessary for terrorist acts to terrorists,” and Proliferation Financing refers to “the act of providing funds or financial services to persons involved in the development, possession, or export of weapons of mass destruction, etc., who are subject to asset freeze measures.” Allowing Money Laundering, etc. to go unchecked means permitting criminal proceeds to be used for future criminal activity and enabling criminal organizations to exert influence over legitimate economic activities. Preventing Money Laundering, etc. is therefore an important domestic and international challenge. Furthermore, Money Laundering, etc. has become increasingly globalized, sophisticated, and complex in recent years, making international cooperation essential for its prevention.

*3 Compliance with Foreign Exchange and Foreign Trade Laws refers to adherence to the “Foreign Exchange and Foreign Trade Act,” the “Act on Prevention of Transfer of Criminal Proceeds,” and related government ordinances, ministerial ordinances, and regulations (collectively referred to as Foreign Exchange Laws), as well as socially accepted norms.