FinShot Inc. (hereinafter referred to as “the Company”) positions Anti-Money Laundering and Counter-Terrorist Financing (hereinafter “AML/CFT”) as one of the highest priorities in corporate management. The Company’s management takes the lead in addressing AML/CFT-related challenges and works to establish a sustainable management framework in line with the policies outlined below.

1. Management Involvement and Risk Management

The Company’s management recognizes AML/CFT as a critical aspect of its business strategy and considers it a foundation for long-term growth and corporate value enhancement. AML/CFT-related issues and measures are regularly reviewed and evaluated, and all policies and procedures are finalized with the approval of management.

2. Risk Assessment and Mitigation for AML/CFT

Based on the Risk-Based Approach (RBA), the Company identifies and assesses risks associated with the services and operations it provides, implementing appropriate risk mitigation measures accordingly. Additionally, the Company pursues a flexible response informed by the latest trends and characteristics of the risks.

3. Employee Training

All employees undergo fundamental AML/CFT training and strive to acquire the expertise necessary for their roles and responsibilities.

4. Documentation and Record Management

Customer identification documents, transaction records, and key AML/CFT-related documents are retained in compliance with applicable laws and regulations. These records are securely managed through a robust system.

5. Use of IT Systems and Data Management

To effectively implement AML/CFT, the Company employs state-of-the-art IT systems to automate transaction monitoring and data management. Data is securely stored, and external access is strictly controlled. Customer Risk Profiles (CRP) are utilized to analyze transaction data and detect suspicious activities in real time.

6. Customer Management and Transaction Transparency

The Company ensures compliance with applicable laws and regulations through thorough Know Your Customer (KYC) procedures. Continuous customer management is conducted to eliminate relationships with sanctioned individuals or antisocial forces, ensuring transparent transactions. Based on relevant laws, applications for overseas remittances require verification of personal numbers (My Number), and for non-Japanese nationals, residence cards are checked to confirm residence periods.

7. Group-Wide Risk Management

The Company rigorously manages AML/CFT risks in collaboration with partner companies. A unified standard for risk evaluation and response is applied across the group, and partner compliance with AML/CFT requirements is regularly inspected. Additional management and support are provided as necessary.

8. Integration into Business Strategy

Risk management, including AML/CFT, serves as a foundation for the Company’s long-term growth and corporate value enhancement, positioning it as a core business strategy. Topics related to AML/CFT are regularly discussed at management and executive meetings to evaluate their effectiveness.

9. Strengthening Systems and Continuous Improvement

The Company periodically reviews its AML/CFT framework and promptly implements improvement measures based on the results of internal and external audits. Under strong management commitment, the Company builds a flexible management system capable of addressing future risks.

FinShot Inc. is committed to contributing to a sustainable financial ecosystem through its AML/CFT initiatives.

FinShot Inc.