Anti-Money Laundering (Aml) & Counter-Terrorist Financing (Ctf) Statement
Effective Date: June 4, 2025
Company: Clifton Vogel
Corporate Seat: Tokyo, Japan
Our Institutional Mandate
Clifton Vogel is strictly committed to preventing the global financial system from being used for illicit activities. As a direct-custody wealth advisory and transaction management firm based in Tokyo, Japan, we operate under a rigorous framework designed to detect, mitigate, and report any activities related to money laundering, terrorist financing, or proliferation financing.
Our compliance program is built in strict accordance with Japan’s of Act on Prevention of Transfer of Criminal Proceeds, guidelines issued by the Financial Services Agency (FSA) of Japan, and the international recommendations of the Financial Action Task Force (FATF).
1. Robust Client Due Diligence (CDD) & Know Your Customer (KYC)
Before establishing any account relationship, accepting any assets into direct custody, or executing any private market transactions, Clifton Vogel performs comprehensive corporate and personal due diligence.
- Identity Verification: We verify the identity of all individual private clients, corporate officers, charity trustees, and authorized signatories using verified, government-issued documentation.
- Beneficial Ownership: For corporate entities, trusts, charities, and endowments, we conduct deep-dive tracing to identify the ultimate beneficial owners (UBOs) and individuals exercising controlling interest.
- Purpose of Relationship: We require clear documentation detailing the nature, intended purpose, and scope of the financial relationship with Clifton Vogel.
2. Verification of Source of Wealth & Source of Funds (SoW / SoF)
To preserve the integrity of our direct custody infrastructure, Clifton Vogel does not accept anonymous accounts, shell-company structures lacking economic substance, or unverified capital injections.
- Forensic Verification: Clients may be asked to provide transparent, verifiable documentation establishing the legitimate economic origin of their wealth (e.g., corporate sale proceeds, inheritance tracking, corporate dividend history, or institutional endowment grants).
- Direct Asset Lineage: Any capital or assets transferred into our segregated custody structures must originate from verified financial accounts held in the explicit name of the onboarded client or entity.
3. Continuous Monitoring & Screening Architecture
Clifton Vogel maintains an ongoing, systematic monitoring framework to assess risk throughout the lifecycle of the relationship:
- Sanctions and PEP Screening: All individual and institutional profiles are continuously screened against international sanctions lists (including United Nations, Japanese Ministry of Finance, US OFAC, and EU lists) as well as Politically Exposed Persons (PEP) databases.
- Transaction Surveillance: We monitor account movements and asset transfers for anomalous patterns, jurisdictional inconsistencies, or deviations from the client’s established economic profile.
4. Regulatory Reporting & Governance
In compliance with Japanese statutory obligations, Clifton Vogel maintains absolute autonomy in its regulatory duties.
- Suspicious Activity Reports (SARs): Where transaction monitoring or due diligence uncovers indicators of potential financial crime, Clifton Vogel is legally mandated to report such findings to the relevant Japanese financial intelligence units, without prior notification or disclosure to the client (“anti-tipping off” compliance).
- Record Retention: All KYC documentation, verification records, transaction logs, and corporate due diligence files are stored securely in encrypted, ring-fenced environments for a minimum statutory period of seven (7) years following the termination of the client relationship.