Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy
Peninsula Assets Management
Tokyo, Japan
Last Updated: November 17, 2025
Commitment to Financial Integrity
Peninsula Assets Management (“Peninsula,” “we,” “us,” or “our”) is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in all aspects of its operations.
We have established policies and procedures designed to prevent the misuse of our services for:
- Money laundering
- Terrorist financing
- Proliferation financing
- Fraud or other financial crime
Our framework is designed in accordance with applicable Japanese laws and international standards.
Regulatory Framework
Peninsula’s AML/KYC framework is designed to meet both domestic regulatory requirements in Japan and internationally recognized standards applicable to firms serving a global clientele.
Our compliance program operates in accordance with:
- The Act on Prevention of Transfer of Criminal Proceeds (Japan)
- The Financial Instruments and Exchange Act (Japan)
- Guidelines and supervisory expectations of the Financial Services Agency of Japan (JFSA)
- Standards issued by the Financial Action Task Force (FATF)
- Applicable United Nations Security Council resolutions
- Relevant sanctions regimes administered by competent authorities in jurisdictions where we conduct business
- Cross-border AML/CFT obligations applicable to international financial institutions
In addition, where required by client domicile, transaction structure, or counterparty exposure, Peninsula aligns its internal controls with internationally recognized compliance principles, including:
- Risk-based customer due diligence standards
- Beneficial ownership transparency requirements
- Enhanced due diligence for higher-risk jurisdictions
- Global sanctions screening protocols
- International information-sharing obligations where legally permissible
Peninsula continuously monitors regulatory developments across relevant jurisdictions and updates its policies and procedures to reflect evolving global AML/CFT expectations.
Risk-Based Approach
Peninsula applies a risk-based approach to anti-money laundering and counter-terrorist financing (AML/CFT). This approach includes:
- Identification and assessment of inherent risks
- Client risk classification
- Enhanced due diligence for higher-risk relationships
- Ongoing transaction monitoring
- Periodic review of client profiles
Risk factors considered include jurisdiction, client type, transaction structure, source of funds, and beneficial ownership complexity.
Customer Due Diligence (CDD)
Prior to establishing a business relationship, Peninsula conducts customer due diligence procedures that may include:
Identity Verification
Verification of a client’s identity using reliable, independent documentation, which may include:
- Government-issued identification
- Corporate registration documents
- Proof of address
- Tax identification information
Beneficial Ownership
For legal entities, we identify and verify ultimate beneficial owners and controlling persons in accordance with Japanese regulatory requirements.
Purpose and Nature of Relationship
We assess:
- Intended investment objectives
- Source of funds
- Expected account activity
- Business rationale
No account or investment relationship will be established unless required identification procedures are satisfactorily completed.
Enhanced Due Diligence (EDD)
Enhanced due diligence measures are applied where heightened risk is identified, including but not limited to:
- Politically Exposed Persons (PEPs)
- Clients from higher-risk jurisdictions
- Complex ownership structures
- Unusual or large transactions inconsistent with known profiles
EDD may include:
- Additional documentation
- Independent verification
- Senior management approval
- Ongoing heightened monitoring
Ongoing Monitoring
Peninsula conducts ongoing monitoring of client relationships to ensure that transactions are consistent with:
- The client’s known profile
- Source of funds
- Stated investment objectives
- Risk classification
Transactions or activity that appear unusual, suspicious, or inconsistent may trigger internal review procedures.
Suspicious Transaction Reporting
Where Peninsula identifies suspicious activity, we will comply with applicable legal reporting obligations, including reporting to competent authorities as required under Japanese law.
We do not disclose to clients when a suspicious transaction report has been filed, except where permitted by law.
Recordkeeping
In accordance with regulatory requirements, Peninsula maintains records of:
- Identity verification documentation
- Transaction records
- Risk assessments
- Compliance reviews
Records are retained for the period required under applicable Japanese laws and regulations.
Sanctions Compliance
Peninsula maintains procedures designed to ensure compliance with:
- Japanese sanctions regulations
- United Nations sanctions
- Other applicable international sanctions regimes
We screen clients and counterparties against relevant sanctions lists and may refuse or terminate relationships where required.
Training and Governance
Peninsula maintains internal governance controls including:
- Appointment of a responsible compliance officer
- Periodic AML/CFT training for relevant personnel
- Independent testing or internal review processes
- Regular updates to policies to reflect regulatory changes
Senior management maintains oversight of the AML/CFT framework.
Refusal or Termination of Relationships
Peninsula reserves the right to:
- Decline to establish a client relationship
- Suspend transactions
- Terminate existing relationships
where identification requirements are not met, required information is not provided, or financial crime risks cannot be satisfactorily mitigated.
Client Cooperation
Clients are required to:
- Provide accurate and complete information
- Notify Peninsula of material changes
- Cooperate with reasonable due diligence requests
Failure to cooperate may result in delayed services or termination of the relationship.
Updates to This Policy
This AML/KYC Policy Disclosure may be updated periodically to reflect regulatory developments or enhancements to our compliance framework.
Contact Information
For compliance-related inquiries, please contact:
Peninsula Assets Management
Tokyo, Japan
info@pen-assets.com