【Compliance Station®UBO＋Case Studies】​

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Client Profile​

MS&AD Insurance Group Holdings, Inc. (Tokyo)​

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Business Sector：​
Non-life Insurance Business、Life Insurance Business、Corporate Financing​

Services :​
Beneficial Owner Check Tool (Compliance Stationン®UBO)

Challenges and Benefits
Challenges​

・Collecting information on ultimate beneficial owners (UBOs) of counterparties not required by law is traditionally manual, time-consuming and difficult.​

・The third-party service previously used only provided data once a year, making it challenging to respond to urgent needs such as new business deals.​

・The fixed timing for data acquisition meant workloads were heavily concentrated at certain times.​

 

Benefits

・Enables access to corporate information, including UBOs, that is difficult to obtain through in-house research, allowing for more robust risk assessments.​

・The online tool allows businesses to check information as needed and in the required amount, achieving workload leveling.​
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・The intuitive interface makes it possible to quickly acquire UBO information with minimal data input.​

・The ability to handle both bulk and transaction-based data acquisition enables timely and flexible data usage depending on business needs.​

The Interviewee
Mr. Takeshi Matsuda​

MS&AD Insurance Group Holdings, Inc.​
Compliance Dept., Director and ​
Mitsui Sumitomo Insurance Company, Limited

Ms. Naoko Aoki

Aioi Nissay Dowa Insurance Co., Ltd.​
Compliance Dept., Assistant Manager

Mr. Tadashi Miura​

Mitsui Sumitomo Aioi Life Insurance Company, Limited​
Compliance Dept., Deputy Director

Mr. Naohito Ichikawa​

Mitsui Sumitomo Primary Life Insurance Company, Limited​
Compliance Dept.,Supervisor

Business Overview: Leading the Domestic and Global Insurance Market​


MS&AD Insurance Group Holdings, Inc. (hereinafter “MS&AD Holdings”) is a publicly listed holding company that owns five directly invested domestic insurance companies and eight affiliated business companies. The domestic insurance group comprises three non-life insurance companies and two life insurance companies. MS&AD Holdings achieved the largest share of net premiums written in the domestic non-life insurance market for fiscal year 2023. From a global perspective, it is the only insurance group with direct insurance operations across all 10 ASEAN countries, and it held the top position for total direct insurance premiums within the ASEAN region in fiscal year 2022. As global efforts to combat money laundering (ML) intensify, it has become essential for financial institutions to identify the ultimate beneficial owners (UBOs) of their counterparties. As a specified business operator, MS&AD Holdings is also required to comply with Japan’s Financial Services Agency (FSA) anti-money laundering guidelines.​

ノートパソコンの前に座る男性 AI によって生成されたコンテンツは間違っている可能性があります。

 

“As an insurance group, we fall under the category of specified business operators, which means we are obligated to identify ultimate beneficial owners in accordance with the AML guidelines. Looking ahead to the 5th round of FATF evaluations, the FSA has emphasized the importance of verifying the effectiveness of our own AML measures. We recognize that identifying the ultimate beneficial owners of corporate entities is one of the most critical points in combating money laundering. Although the scope of specified transactions under the Act on Prevention of Transfer of Criminal Proceeds (hereinafter ‘Criminal Proceeds Act’) is limited for our three non-life insurance companies, we go beyond the legal requirements of the Criminal Proceeds Act and identify UBOs based on risk-based assessments as required by the FSA. Given the current national system and the limitations of in-house research, we are currently using the best available method, but we will continue to verify its effectiveness.” ​

(Mr. Matsuda)​

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Challenges and Background: Issues with Data Quality and Timing​​

In conducting due diligence on ultimate beneficial owners (UBOs), MS&AD Holdings previously relied on a third-party service, but they faced challenges in the following areas:​

  1. Workload concentration due to spot checks​
  2. Lack of operational flexibility​

 

“Compliance Station® UBO+” is an online service that enables identification of UBOs of domestic companies in compliance with the Criminal Proceeds Act. It allows users to obtain the necessary information whenever they need it.​

Previously, we received data on a spot basis only once a year. Although the timing of this data acquisition was known in advance, it coincided with other busy periods, so we felt a strong need to even out our workload.” (Mr. Matsuda)​

 

MS&AD Holdings chose “Compliance Station® UBO+” because it directly addressed these challenges.​

“The fact that we can flexibly acquire data at any time during the year based on our own operational needs is a tremendous advantage. Also, the ability to quickly conduct ad hoc investigations when we urgently need UBO information has been extremely helpful.” (Mr. Matsuda)​​

Solutions and Outcomes: Experience of Streamlined Operations through User-Friendly Service and Comprehensive Support​

At MS&AD Holdings, the entire group has implemented “Compliance Station® UBO+.” From the outset, they envisioned rolling out the service across the group, and after service briefings for each group company’s representatives, they quickly reached a consensus for smooth adoption.​

Following implementation, we organized training sessions to ensure a smooth start to operations. Thanks to the intuitive UI/UX design of “Compliance Station® UBO+,” a single explanation was enough for them to begin seamlessly incorporating it into their daily work.​

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“I was transferred to this role this year and used ‘Compliance Station® UBO+’ for the first time. Although there was a gap between the initial training session and when I used it, the intuitive UI/UX made it easy to quickly identify ultimate beneficial owners. The simplicity of the interface has been incredibly helpful.” (Ms. Aoki)​​

The hands-on impressions from users have also been very positive.​

“Even with little information, we can identify candidate companies and see comprehensive UBO data all at once, which is extremely convenient. Previously, when we lacked enough information to search and identify target corporations, we often had to ask other departments for help. If those departments were busy, we ended up finalizing the search target list just before the deadline. Having this resolved is a huge relief.” (Mr. Ichikawa)​​

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By implementing this service, MS&AD Holdings has experienced a tangible improvement in operational efficiency. In particular, the ability to access hard-to-obtain data, such as UBO information, whenever needed has significantly contributed to reducing and leveling out workloads.​​

“We used to have to prepare data within fixed annual deadlines, but now we can work at our own pace. Being able to plan and balance this work alongside our other tasks is a major advantage. ”(Mr. Matsuda)​​​

While the system is designed to be very user-friendly, we have also set up a dedicated support desk to quickly address any questions or issues that may arise.​

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“There was a time when Compliance Station® UBO+ was temporarily unavailable due to issues with the browser used across the MS&AD Holdings. When we reached out to the support desk, they quickly responded, and had it back up and running in about 10 days.” (Mr. Miura)​

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Prospects: Expanding the Use of UBO Data Beyond Initial Compliance​
When obtaining ultimate beneficial owner (UBO) information in-house, the only option is to directly ask the counterparty being investigated. While this might not be an issue for smaller sets of counterparties, for companies like MS&AD Holdings with a large number of counterparties, using “Compliance Station® UBO+” is a more efficient solution.​

“If confirmation of UBOs is required in the insurance contracting process, we do so at that time. However, if it’s not required for a particular contract, it adds an extra step. Since we conduct most of our insurance contracting through insurance agents, obtaining UBO information means first getting their understanding and cooperation. With over 100,000 corporate entities to investigate, it is simply not realistic to do this individually.” (Mr. Matsuda)​

MS&AD Holdings is now considering expanding the scope of UBO investigations and exploring broader applications for this data.​

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“As a group, we are prioritizing investigations of higher-risk entities, but we are not yet able to cover all counterparties. Going forward, we want to broaden the scope and ensure our efforts are even more effective. Currently, we are using ‘Compliance Station® UBO+’ exclusively for UBO investigations. If we receive proposals for other useful features, we’d be very interested in adopting them to make even better use of the tool.” (Mr. Matsuda)​​

 

Summary of the Implemented Service​

Compliance Station® UBO+​

An online service that instantly identifies ultimate beneficial owners and corporate ownership structures in compliance with the Act on Prevention of Transfer of Criminal Proceeds, using Compliance Datalab's proprietary algorithm and leveraging TSR's extensive corporate database of over 10 million records.​

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