Effective Date: May 28,2024
Fairfield Stern (“we,” “our,” “us”) is committed to maintaining the highest standards of integrity in our business and complying with all applicable laws and regulations designed to combat money laundering, terrorist financing, and other financial crimes.
This Anti-Money Laundering (AML) Policy outlines our commitment to safeguarding the financial system and ensuring that our services are not misused for unlawful purposes.
1. Our Commitment
We recognize that as a wealth management firm, we have a responsibility to detect, prevent, and report suspicious activities. We adhere to all relevant laws and regulations in Japan, including the Act on Prevention of Transfer of Criminal Proceeds, as well as applicable international standards.
2. Customer Due Diligence (CDD)
- Collecting and verifying official identification documents.
- Understanding the nature and purpose of the client relationship.
- Conducting enhanced due diligence for higher-risk clients, transactions, or jurisdictions.
3. Ongoing Monitoring
We monitor client accounts and transactions on an ongoing basis to ensure that activities are consistent with our knowledge of the client and the intended purpose of the relationship. Any unusual or suspicious activity will be reviewed and, if necessary, reported to the relevant authorities.
4. Reporting Obligations
We are legally obligated to report certain transactions or activities to the appropriate authorities in if we suspect they may be linked to money laundering or terrorist financing. Fairfield Stern fully cooperates with regulatory and law enforcement bodies in such matters.
5. Record Keeping
In compliance with applicable regulations, we retain client identification records, transaction data, and relevant communications for the legally required period. This enables us to respond promptly to requests from regulators or law enforcement agencies.
6. Employee Training and Awareness
Our employees receive regular training on AML laws, regulations, and internal policies. This ensures that they understand their responsibilities, can recognize suspicious activity, and know how to escalate concerns appropriately.
7. Risk-Based Approach
8. Prohibited Activities
- Money laundering or terrorist financing.
- Shell banks or anonymous accounts.
- Clients involved in criminal or illicit activity.
9. Review of Policy
10. Contact Us
Fairfield Stern
Tokyo, Japan
Email: info@fairfieldstern.com