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Compliance Procedures in Banking in Japan: A Trust Bank’s Approach to Ensuring Thorough Compliance
MTBJ, a bank committed to being truly trusted and valued by society, has developed measures and systems aimed at ensuring thorough compliance. At the heart of its philosophy is the formulation of Corporate Activity Ethics Standards, which clarify its basic policy on compliance with laws and regulations as well as specific standards of conduct.
Compliance Manual
To practice compliance, MTBJ has formulated a Compliance Manual that serves as a specific guide for all officers and employees. The manual is posted on the intranet and training is conducted at the workplace to ensure understanding.
Annual Compliance Program
The bank also formulates an Annual Compliance Program, which outlines its compliance activities and progress for each fiscal year.
Strengthening AML Structure
To further strengthen its anti-money laundering (AML) structure, MTBJ has enhanced its AML system by:
- Including electronic messages for cash and securities settlement in international settlement screening
- Strengthening know your customer control
The bank regularly conducts compliance training and checks matters related to laws and regulations.
Organizational Structure for Compliance
MTBJ’s organizational structure for practicing compliance includes a Compliance Committee chaired by the Director in charge of the Corporate Risk Management Division, as well as a Corporate Risk Management Division that plans and proposes measures for practicing company-wide compliance. Each division also has a Compliance Officer appointed to practice compliance at the division level.
Compliance Helpline
The bank has established a system known as the Compliance Helpline, which allows employees to directly report any compliance issues to an internal or external reporting desk. Upon receiving a report, the Corporate Risk Management Division takes action, including:
- Clarifying facts
- Correcting problems
- Developing preventative measures
Internal Control System
The bank’s internal control system includes:
- Risk Management System
- Compliance System
- International Standard Certification for Information Security Management System
- Internal Audit System
- External Audit System
MTBJ believes that these systems are essential in ensuring thorough compliance with laws and regulations, as well as maintaining the trust of its customers and stakeholders.