Customer Identification Process (KYC)

Life insurance companies and related organizations (including life insurance agencies) are required by law 1 to verify the identity of customers—including their name, residential address, and date of birth—as well as the purpose of the transaction, occupation or business details, and, in the case of corporate customers, the beneficial owner when entering into life insurance contracts or similar agreements.


This requirement is intended to prevent financial institutions and other entities from being used for terrorist financing or money laundering 2 by ensuring proper recordkeeping of customer transactions.


We kindly ask for your understanding and cooperation in this matter.


Notes:

  1. Act on Prevention of Transfer of Criminal Proceeds (APTCP)
  2. The act of disguising “dirty money” obtained through criminal activities as “clean money” obtained through legitimate transactions.

1. About the Customer Identification Process

FP Partner Inc. verifies the following information for each customer: personal identification details (name, residential address, date of birth, etc.), the purpose of the transaction, occupation or business details, whether the customer holds an important public position in a foreign government or similar organization, and, in the case of corporate customers, the beneficial owner.


In addition, for transactions that pose a high risk of money laundering—such as those suspected of identity theft or fraud—we use more stringent methods than for ordinary transactions to verify identity information and other details. We also confirm the customer’s assets and income status for transactions involving the transfer of property exceeding 2 million yen.


If there are any changes to the information you provided during the customer identification process or to your personal identification details, please contact FP Partner Inc. or the life insurance company with which you took out your policy.

(1) Personal Identification Information

For individual customers, we verify the customer’s name, residential address, and date of birth.


For corporate customers, we verify the company name and the location of the head office or equivalent.
Verification is conducted using the following methods.

i. Individual Customers
  • We verify your identity by asking you to present or send a copy of an official identification document. Acceptable documents include a driver’s license, health insurance card, national pension handbook, passport, Individual Number Card (My Number Card), or a Seal Registration Certificate if you use your registered seal for transactions.
    If you present an identification document without a photo, such as a health insurance card,
    we may ask you to provide additional documents—such as another form of identification or a utility bill—to further confirm your identity.
    Note: Depending on the type of identification document you provide, we may need to confirm that insurance policies or other transaction-related documents have been delivered to your registered address.
  • If you conduct transactions through an agent, we need to verify the identity of both you and your agent.
ii. Corporate Customers
  • We verify the identity of both the corporate customer and the individual who conducts the actual transaction (for example, the person visiting our office).
    The identification process for the individual handling the transaction is the same as that for individual customers.
  • For the corporate customer itself, we verify identity by asking you to present or send documents such as a Certificate of Registered Matters or a Seal Registration Certificate.

(2) Purpose of the Transaction

We confirm the purpose of your transaction—such as securing death benefits or preparing for retirement when concluding an insurance contract—based on the information you provide.

(3) Occupation or Business Details

For individual customers, we verify your occupation (for example, company employee, civil servant, self-employed individual, or homemaker).


For corporate customers, we verify the nature of your business (for example, manufacturing, construction, or finance).


Verification is conducted using the following methods:

i. Individual Customers
  • For individual customers, we confirm this information based on the details you provide.
ii. Corporate Customers
  • For corporate customers, we confirm this information using documents such as the company’s articles of incorporation, Certificate of Registered Matters, or other relevant materials.

(4) Whether the Customer Holds an Important Public Position in a Foreign Government or Similar Organization

When conducting transactions with individuals who hold an important public position in a foreign government or a similar organization, we may ask you to provide additional proof of identity, such as multiple forms of identification.

Note: In addition to procedures that differ from the standard identification process, we may also need to confirm your assets and income status.

i. Transactions Requiring Additional Proof of Identity
  • Transactions with individuals who hold an important public position in a foreign government or a similar organization
  • Transactions with family members of individuals who hold an important public position in a foreign government or a similar organization
  • Transactions with corporate customers whose beneficial owner (for example, an individual who holds more than one-fourth of the total voting rights of the corporation, such as a major shareholder) is an individual who holds an important public position in a foreign government or a similar organization, or a family member thereof
ii. Meaning of the Term Individuals Holding an Important Public Position in a Foreign Government or Similar Organization

In addition to foreign heads of state, the term “individuals holding an important public position in a foreign government or similar organization” refers to individuals who hold important public positions in a foreign government, central bank, or other comparable institution.


Specifically, this includes individuals in the following positions (including those who have previously held such positions):

  • Prime Minister, Ministers of State, and Vice Ministers
  • Speaker and Deputy Speaker of the House of Representatives, and President and Vice President of the House of Councilors
  • Justice of the Supreme Court
  • Ambassador Extraordinary and Plenipotentiary, Minister Extraordinary and Plenipotentiary, Special Envoy, Government Representative, and Plenipotentiary
  • Chief and Vice Chief of Staff of the Joint Staff, and Chiefs and Vice Chiefs of Staff of the Ground, Maritime, and Air Self-Defense Forces
  • Executives of a central bank
  • Executives of corporations whose budgets are subject to approval or authorization by the national assembly of that country

(5) Beneficial Owner

A beneficial owner (such as a major shareholder) refers to an individual who is recognized as having a dominant influence over the business activities of a corporation, for example, by directly or indirectly1 holding more than 25% of the corporation’s voting rights (shares, etc.).2


Notes:

1. Indirect holding refers to holding shares through a controlling corporation that possesses more than 50% of the voting rights.

2. If there is more than one individual who falls under this category, please declare all such individuals.

If an individual holds more than 50% of the voting rights or has the right to receive more than 50% of dividends or distributions, that individual will be regarded as the beneficial owner. An individual who, due to illness or other reasons, lacks the intent or ability to exercise effective control over a corporate customer, or who is unable to perform business operations, does not qualify as a beneficial owner (such as a major shareholder).

Although beneficial owners are defined as individuals, states, local governments, listed companies, and their subsidiaries are also regarded as individuals.



2. When Customer Identification Is Required

We carry out the customer identification process in the following situations:

  1. Transactions involving the conclusion of a life insurance contract, provision of policyholder loans, change of policyholders, or payment of maturity benefits, annuities, or surrender values
  2. Transactions involving cash or other assets with a value exceeding 2 million yen (Even if the amount is 2 million yen or less, it will be regarded as a single transaction if it is clearly evident that the transaction has been divided into smaller parts to reduce the amount per transaction.)
  3. Transactions involving property suspected of being obtained through criminal activities
  4. Transactions conducted in a manner that differs significantly from the way similar transactions are normally conducted

Note: Some transactions or products that would normally require customer identification at the time of transaction may be exempt.

Please contact your representative for details.

3. When Customer Identification Has Already Been Completed

Once FP Partner Inc. has verified your identity through a previous transaction, additional customer identification may not be required for subsequent transactions if your identity can be confirmed using your insurance policy, card, PIN (password), or other similar means.

Note: Please contact your representative for details.

4. When a Customer Makes a False Declaration

The Act on Prevention of Transfer of Criminal Proceeds prohibits customers from making false statements related to the customer identification process.

If a customer intentionally conceals their identification information and violates this provision, they may be subject to imprisonment for up to one year, a fine of up to one million yen, or both.

5. Exemption Provisions for Financial Institutions

The Act on Prevention of Transfer of Criminal Proceeds provides that financial institutions and similar entities may refuse to fulfill transaction-related obligations until customers complete the customer identification process if they initially refuse to do so.


Accordingly, customers cannot demand that financial institutions perform contractual obligations while they have not completed the customer identification process.


FP Partner Inc. will not use any personal information obtained from customers under the Act on Prevention of Transfer of Criminal Proceeds for any purpose other than those required by the Act.