Basic Policy on Anti-Money Laundering and Anti-Terrorist Financing

Binance Japan (“Binance Japan”, the “Company”, “we”, or “us”) will comply with applicable laws and regulations to prevent money laundering and the financing of terrorism ("money laundering, etc.") and will ensure the appropriateness of its business operations. (hereinafter referred to as "the Company") has established the following basic policy and control system to prevent money laundering and terrorist financing (hereinafter referred to as "money laundering, etc."), to comply with applicable laws and regulations, and to ensure the appropriateness of its business operations.

Management Issues

The Board of Directors of the Company shall position countermeasures against money laundering, etc. as one of the most important management issues, and shall establish a system that enables the organization to respond appropriately and in a timely manner.

Organizational Structure

The Compliance Department, which is the department in charge of compliance, will work in cooperation with each department in order to take measures against money laundering, etc. The director in charge of compliance will be the general manager.

 Risk-Based Approach

Based on the risk-based approach, we will identify and evaluate risks related to money laundering, etc. that we face, and take mitigation measures commensurate with the risks.

User Management Policy

We will implement timely and appropriate confirmation at the time of transactions and other checks, and establish a system to implement countermeasures in line with the attributes of users, etc. In addition, we will periodically check the transaction records of users to determine whether there is any risk of money laundering, etc. In addition, we will conduct periodic investigations and analysis of users' transaction records, and review countermeasures.

 Notification of Suspicious Transactions

We will monitor suspicious transactions, and if we detect a suspicious transaction, we will establish an internal system to report it to the authorities in a timely and appropriate manner.

 Economic Sanctions (Asset Freeze, etc.)

We will confirm the economic sanctions (asset freeze, etc.) and, from the perspective of preventing money laundering, etc., we will take measures such as the termination or cancellation of transactions as necessary.

 Implementation of Training, etc.

The Company shall provide guidance and training to its officers and employees to deepen their knowledge of the prevention of money laundering, etc. and to make them aware of the importance of such prevention.

 Compliance Audits

We will conduct internal audits of our internal systems for the prevention of money laundering, etc. on a regular basis, and strive to improve our internal systems based on the results of such audits.

 Implementation of PDCA Cycle

We will verify the effectiveness and efficiency of measures to prevent money laundering, etc., and continuously strive to improve our anti-money laundering system.

※ The English version is a referential translation of the original Japanese version of the Policy. In the case of discrepancy between the English version and the original Japanese version of the Policy, the original Japanese version shall prevail.