June 15, 2018 Disposition to General Incorporated Association Financial Futures Association Members Today, the Association took the following dispositions against members of the Association based on Article 19, Paragraph 1 of the Articles of Incorporation. Note I. SBI FX Trade Co., Ltd. 1. Name of the association member who received the disposition SBI FX Trade Co., Ltd. 2. Disciplinary action Remarks 3. Reasons for disposition The former representative director (hereinafter referred to as the "actor") opened a FX account for a member of the Association in July 2000, before he assumed the position of representative of the company, and from June 29, 2016 to October 17, 2017. From 10,000 to 2,000,000 currencies in foreign exchange margin trading (FX trading) in 12 currency pairs. The background of this violation is that the offender has been opening it for a long time against the background of the irregular market environment after the June 24, 2016 "referendum on whether the United Kingdom should leave the European Union". In addition to the investor's asset management, there was also the purpose of confirming the trading environment of other companies in the FX account of the association member, and it was the opportunity to make a transaction. As for the cause of occurrence, Article 4 (Prohibited Acts) No. 3 of the Association's "Regulations Concerning the Service of Employees Engaged in Financial Futures Trading Business" stipulates that "regardless of the name, in one's own account Conducting financial futures transactions, etc., handled by affiliated members." However, the part "affiliated member" refers to the company itself, and only transactions within the company are prohibited, and the person doing the transaction is a transaction at another company. I understand that it is not prohibited. The interpretation of item 3 of the same article is described in the Q&A of the Association's "Financial Futures Trading Operation Manual," and the person involved was not aware of the contents of this Q&A. <(Reference) Financial Futures Trading Operation Manual Q&A> “(Omitted) Officers and employees engaged in FX operations shall It is prohibited to engage in FX (regardless of whether it is an exchange or over-the-counter). (e.g. lending business, etc.), this provision does not apply.” The company’s employee service regulations prohibit foreign exchange margin trading for all employees. did not comply with the employee service regulations, so the perpetrator could not correct the above misconception. The background to the misunderstanding of this violation is that, in 2012, when the company first opened, the perpetrator was the former representative director and president. It is said that he was told that he had confirmed with the Association that there was no need to close and that he could continue to hold FX positions. could not. According to the company's compliance manual 5-2 (prohibition of transactions by officers and employees), the company's officers and employees shall use the over-the-counter currency Derivatives trading is prohibited.", but there is no statement that trading with other companies is also prohibited, so it seems that the officers and employees of the company are not prohibited from performing FX trading with other companies. There was room for misunderstanding. For this reason, the actors misunderstood that FX trading at other companies was not a prohibited matter because it did not fall under conflicts of interest such as local trading, local receiving, insider trading, and front-running, unlike securities trading. The company had failed to inform its executives that, because the company specializes in FX, it is prohibited to engage in financial futures transactions, etc. handled by other members. As a measure to prevent recurrence, at the Compliance Committee meeting held on November 14, 2017, we explained the rules (compliance manual) of the association and the company to the committee members, including full-time directors, All executives and employees were instructed that FX transactions were prohibited in their company and other companies, and when it was confirmed that other executives were not engaging in similar transactions, no similar cases had occurred. Considering these facts, the perpetrator, despite his position as the representative director of the company, had insufficient awareness of laws and regulations, and in addition to managing his own assets, he was conducting transactions for the purpose of confirming the trading environment of other companies. In addition, regarding the company's internal control system, it was confirmed that the company's legal compliance system was inadequate. 4. In addition to this disposition, on the same date, based on Article 16 of the Articles of Incorporation, we made a recommendation to thoroughly comply with laws and regulations and to enhance and strengthen the internal control system. II. Money Square Co., Ltd. 1. Name of the association member who received the disposition Money Square Co., Ltd. 2. Contents of disciplinary action Negligence fine of 5 million yen 3. Reason for disposal ・ The company recognized that the web server that constitutes the company's website was overloaded on July 13, 2017, and as a result of investigating the log of the company's web server, It was confirmed that there was a cyber attack (SQL injection) from the outside from the 13th to the 13th, and 2,388 personal information of customers was leaked. Based on this, a third-party organization requested by the company to investigate investigated the logs of the web server stored by the company, and found that in July, August and November of the same year, the company received a total of As many as 144,423 cyberattacks were carried out, and it was found that 112,344 cases of personal information were leaked as a result (hereinafter referred to as the "Information Leakage Incident").・ In response to this information leakage incident, the director of the Kanto Local Finance Bureau reported to the company on the formulation and implementation status of recurrence prevention measures based on analysis of the cause of occurrence, based on the provisions of Article 56-2 of the Financial Instruments and Exchange Act. is ordered.・ In response to the above order, the company has submitted an improvement report to the director of the Kanto Local Finance Bureau. It is recognized that it is important to implement and establish recurrence prevention measures.・ In consideration of the above, the information leakage incident had a large impact on customers, and deficiencies related to the company's personal information management system and system risk management system were recognized.In addition, the information leakage incident had a large impact on the FX industry. it is conceivable that. 4. In addition to this disposition, on the same date, based on Article 16 of the Articles of Incorporation, we made a recommendation to thoroughly comply with laws and regulations and to enhance and strengthen the internal control system. that's all