1
Undergo a pre-contract review
2
Sign a basic money trust agreement
3
Deposit trust funds in a trust account
4
Instruct us to purchase real estate
5
Pay taxes and public dues
6
Receive and transfer profits
7
Reinvest or exit the SBIST scheme
1
Undergo a pre-contract review
Estimated time required: about 1 week
First, an interested investor needs to meet with a CastGlobal Trust representative to discuss the SBIST scheme, have their concerns addressed, and prepare thoroughly before entering into a contract with our company. It is also when we conduct anti-money laundering checks. This phase typically takes about one week.
Anti-money laundering checks
As a professional organization entrusted with handling client funds, our company strictly adheres to the recommendations of the Financial Action Task Force (FATF), Japan’s Act on Prevention of Transfer of Criminal Proceeds, and other relevant laws and guidelines to ensure we implement stringent anti-money laundering (AML) and counter-terrorism financing (CTF) measures.
"Our company strictly adheres to ... stringent anti-money laundering and counter-terrorism financing measures"
As of June 2024, the FATF has members from 38 countries and two regions, including Japan, Mainland China, Hong Kong, and Singapore. It has established 40 recommendations as international standards for AML and CTF measures, which are evaluated among member countries and regions. Japan’s Act on Prevention of Transfer of Criminal Proceeds was enacted to comply with these recommendations. It outlines the minimum procedures financial institutions must follow. As a trust company, we are required to adhere to these international standards and laws.
We ask investors to provide us with information to be used for different kinds of validation as part of our Customer Due Diligence (CDD), under our AML policy, and identity verification, before the basic contract can be signed.
Complete a checklist
Prospective clients who would like to invest through CastGlobal Trust are required to complete a checklist we provide that asks for information about a number of details, including:
- Individual investors
Name, date of birth, address, occupation, purpose of the transaction - Corporate investors
Company name, address of the head office or principal office, business activities, purpose of the transaction, transaction representative, ultimate beneficial owner
Submit documents (corporations only)
Prospective corporate clients are required to submit these additional documents:
- Certificate of incorporation, certificate of registered matters, memorandum of association, and articles of association
- Documents proving the authority of the transaction representative
- Shareholder register; or, if the company’s shares are held by another corporation, a shareholder structure chart identifying the ultimate beneficial owner
Present ID
Both potential individual clients and corporate clients, including the ultimate of corporations and corporate transaction representatives, are required to present CastGlobal Trust with identification for verification. As the original ID must be verified, a face-to-face meeting with our representative is generally required at a location where our company has an office.
For clients residing in areas where a face-to-face meeting with our representative is difficult or prohibitively expensive, we will arrange a meeting with a trusted lawyer in the investor’s area or a nearby region.
If a meeting is not possible by any means, we will not be able to proceed with the transaction.
Undergo a background check
We will conduct a background check using specialized tools and may request additional documentation in the following situations:
- If we find any background details that cause concern (including cases where the information provided by the prospective client matches that of another individual with the same name)
- If the amount to be invested is disproportionately high compared to the client’s income or other similar factors
- If any other factors lead us to suspect the transaction may be questionable
If any concerns cannot be resolved, we will not be able to proceed with the transaction.
We do not accept cash deposits
Japanese law limits the amount of cash that can be brought into Japan, and other countries have regulations on sending large amounts of cash out of the country. To comply with these laws — in the interest of eliminating suspicious transactions — we have adopted a strict policy of never accepting cash.
When we refuse transactions
To prevent money laundering, we adopt a risk-based approach: we identify and evaluate risks through the steps mentioned above and, if the risks are initially deemed too high, we will take further risk mitigation measures. However, even after we have taken these further steps, if we still believe the risk remains high, we may have to refuse or discontinue the transaction. We will do so in the following situations:
- If doubts remain unresolved during the identity verification and customer due diligence (CDD) steps
- If a prospective client proposes any of the following high-risk methods of delivering funds and/or being paid, which are likely to be classified as suspicious transactions:
- Asking to pay or be paid in cash
- Making transfers from an account that is not in the name of the settlor or beneficiary
- Proposing that money in their trust account, which was established to hold or sell real estate, is transferred to make payments to entities unrelated to the real estate or real estate transactions
- Asking to have transfers of dividend payments or residual funds sent to an account that is not in the name of the beneficiary at the end of an SBIST project
As advances in IT and the globalization of financial services transform transaction methods, money laundering techniques are evolving and we need to remain vigilant, so we are grateful to all prospective clients for their cooperation during this phase.
