AML Policy (Anti-Money Laundering Policy)

1. Introduction and Policy Objectives

366 Advisory Co., Ltd. (hereinafter referred to as "the Company") operates "Sakura Link," a service that supports the transfer of educational funds to overseas educational institutions, in collaboration with Manual-Arts Pte Ltd, a Singapore-licensed money remittance service provider.

This Policy has been established to appropriately manage and mitigate the risks of money laundering and terrorist financing, and to comply with relevant laws and regulations in the educational fund remittance service provided by the Company.

2. Scope of Application

This Policy applies to all officers, staff, and related personnel engaged in the educational fund remittance service jointly operated by the Company and its partner Manual-Arts Pte Ltd, as well as related business operations.

3. Legal Background and Governing Law

The Company implements AML measures in compliance with the following laws and regulations:

・Japan's "Act on Prevention of Transfer of Criminal Proceeds"
・Relevant financial regulations in Singapore, as applicable to Manual-Arts Pte Ltd
・International AML standards (e.g., FATF Recommendations)

4. Policy on the Division of Responsibilities for Remittance Transactions

The Company and Manual-Arts Pte Ltd allocate business as follows according to the nature of remittances.

【Outbound Remittances (Origin: Japan → Destination: Overseas Educational Institutions)】
KYC: Manual-Arts Pte Ltd, as the license holder, leads recipient verification and management, while the Company conducts KYC for Sakura Link users, and both companies provide and share complementary information as needed
Remittance Execution: Manual-Arts Pte Ltd executes remittances to schools, etc.
Records and Reporting: Main transaction records and reporting responsibilities belong to Manual-Arts Pte Ltd, and the Company also maintains records within the applicable scope

【Inbound Remittances (Origin: Overseas → Destination: Japanese Educational Institutions)】
KYC: Manual-Arts Pte Ltd obtains and manages remitter information, while the Company maintains verification and complementary information for Japanese recipients (educational institutions)
Remittance Execution: The Company executes fund distribution to educational institutions within Japan
Records and Reporting: Both parties share information to maintain the integrity of the entire transaction and fulfill reporting obligations as needed

5. Risk-Based Approach

Risk assessment documents for AML/CFT (Anti-Money Laundering/Counter-Terrorist Financing) are created and maintained based on user attributes (age, nationality, source of funds), destination countries, transaction amounts, etc. This risk assessment is reviewed and updated in principle once a year, or when there are significant changes in products, services, customers, geographic targets, etc.

If there are changes in risk assessment, the compliance program itself may be revised as needed.

Following industry best practices and standards, the compliance officer reconfirms this documented risk assessment and program in principle once a year.

6. Customer Due Diligence (KYC) Handling and Procedures

The Company and Manual-Arts Pte Ltd store and manage KYC information in their respective environments. To prevent information discrepancies, regular reconciliation is conducted, and updates are shared between both parties. All data is protected by access control and encryption, and complies with relevant personal information protection regulations.

The Company conducts KYC (Know Your Customer) through the following processes:

1. Uploading government-issued identification documents by users (e.g., My Number card, passport)
2. Document review by internal review department
3. Identity verification and confirmation of source of funds
4. Proceed to remittance procedures if no issues are found

For corporate customers, corporate registry and Ultimate Beneficial Owner (UBO) information are also subject to verification.

7. Ultimate Beneficial Owner (UBO) Verification

For corporate applicants, we identify Ultimate Beneficial Owners who hold 25% or more voting rights or shares, and verify their identity and relationship. We also verify the consistency of the relationship between fund providers and destination educational institutions.

8. Verification of Legitimacy of Educational Funds

This service assumes that remitted funds are limited to educational purposes such as tuition fees, dormitory fees, and material costs. Users are required to declare the purpose of remittance, and supplementary documents such as tuition invoices or admission permits may be requested as needed.

9. Transaction Monitoring and Suspicious Transaction Reporting

As part of AML (Anti-Money Laundering) and CFT (Counter-Terrorist Financing) measures, we have established a risk-based transaction monitoring system. This system aims to ensure transparency and soundness, taking into account the characteristics of educational fund remittances.

For customers who have completed KYC (Know Your Customer), subsequent remittance transactions are monitored from the following perspectives.

Transaction Volume: Number of remittances per day or week by a certain customer
Transaction Frequency: Concentrated consecutive remittances in a short period (e.g., 5 or more times in one week)
Transaction Amount: Remittances exceeding a certain amount (e.g., 500,000 yen, 1,000,000 yen) or outstanding annual cumulative amounts

Even if no clear illegality is confirmed, if a transaction is found to have no valid explanation or deviates from the normal flow of educational funds, it will be reported to the relevant authorities without delay, as required by applicable laws.(e.g., the Financial Services Agency via the National Police Agency)

10. Economic Sanctions and Sanctions List Compliance

The Company screens counterparties (educational institutions, remitters, related parties) based on sanctions lists from the UN, OFAC (United States), EU, Japan, etc., and avoids transactions with sanctioned persons.

Sanctions list checks are conducted regularly for all customers and transactions using reliable external databases (e.g., World-Check).

11. Handling of Foreign PEPs (Politically Exposed Persons)

For foreign PEPs and their relatives and close associates, enhanced due diligence (EDD) is conducted, requiring approval from senior management.

12. Management of Electronic Remittance Message Information

For all remittances, remitter and recipient identification information is accurately reflected in SWIFT and other messages to ensure remittance traceability.

13. Internal Education and Governance System

The Company regularly conducts internal training to acquire basic knowledge about AML, and staff in relevant departments receive practical training on KYC review and suspicious transaction handling.

Compliance with the AML Policy is regularly reviewed under the supervision of internal responsible persons.

14. Record Keeping and Information Management

The Company retains customer information (KYC documents), transaction history, suspicious transaction investigation records, etc., for a minimum of 5 years from the transaction end date. This information is stored in a form that can be provided upon request from supervisory authorities.

15. Revision and Review

This Policy is reviewed at least once a year in principle, taking into account changes in laws and regulations, changes in business content, external audit results, etc., and is revised and updated as needed.