Checklist for Legal Compliance
I. Development and Establishment of Legal Compliance System by Management
- The development and establishment of a legal compliance system is one of the most important
tasks for a financial institution in order to secure the soundness and appropriateness of its
business. Therefore, the institution’s management is charged with and responsible for taking the
initiative in developing and establishing the legal compliance system that covers the institution’s
entire business by deciding a basic policy on legal compliance and developing an organizational
- The inspector should determine whether the legal compliance system is functioning effectively
and whether the roles and responsibilities of the institution’s Board of Directors are being
appropriately performed by way of reviewing, with the use of check items listed in Chapter I.,
whether the management is appropriately implementing (1) policy development, (2) development
of internal rules and organizational frameworks and (3) assessment and improvement activities.
- If any problem is recognized as a result of reviews conducted with the use of the check items
listed in Chapter II. and later in this checklist, it is necessary to exhaustively examine which of
the elements listed in Chapter I. are absent or insufficient, thus causing the said problem, and
review findings thereof through dialogue between the inspector and the financial institution.
- If the institution’s management fails to recognize weaknesses or problems recognized by the
inspector, it is also necessary to explore in particular the possibility that the Internal Control
System is not functioning effectively and review findings thereof through dialogue.
- The inspector should review the status of improvements with regard to the issues pointed out on
the occasion of the last inspection that are not minor and determine whether or not effective
improvement measures have been developed and implemented.
1. Policy Development
(1) Roles and Responsibilities of Directors
Do directors attach importance to legal compliance based on a full recognition that full legal
compliance throughout the financial institution is vital for maintaining public confidence in the
institution and securing the soundness and appropriateness of the institution’s business? In particular,