JAPAN Trends and Developments Contributed by: Masayuki Atsumi and Yuhei Sakao, Miura & Partners
party in connection with having acted illegally or hav - ing failed to perform an act in the exercise of their duty (Article 197-3 (2)). A bribe knowingly accepted by an offender or by a third party shall be confiscated. A person who gives, offers, or promises to give a bribe, as provided for in Articles 197 through 197-4, is punishable by imprisonment for not more than three years or a fine of up to JPY2.5 million (Article 198). It is worth mentioning that only individuals are subject to bribery regulation under the Penal Code; corpora - tions are not. Recent trends and cases of bribery of domestic public officials Although bribery is a serious economic crime in Japan with severe penalties, as described above, bribery cases continue to occur. In 2025, various bribery cases were uncovered and widely reported. For example, in a bribery case con - cerning the subcontracting of weed removal work at a water purification facility, both the president of a waterworks construction company and a city official were found guilty. Furthermore, in a bribery case concerning a health programme subsidised by the prefecture, a company executive who bribed a prefectural assembly member was found guilty. Tokyo Olympics bribery scandal The most socially impactful bribery case in recent years involved the sponsorship of the Tokyo Olym - pics and Paralympics. In this case, various companies – such as a business suit retail company, an advertis - ing company, a publishing company, and a company manufacturing and selling stuffed toys – gave bribes to a former board member of the Tokyo Olympics Organising Committee. A total of 15 executives of these companies were subsequently indicted for giv - ing bribes. The directors and employees of the Tokyo Olympics Organising Committee, including the board members, are “deemed public officials” under the Act on Special Measures Concerning the Tokyo Olympics and Paralympics. Therefore, the board members are subject to bribery regulation.
The former executives of the business suit retail com - pany were convicted by the Tokyo District Court on 21 April 2023. The former chairperson was sentenced to two years and six months in prison, with a four-year suspended sentence, for the following reasons. • The defendants’ requests in return for bribes to the board member covered a wide range of matters, including the selection of sponsors, and the bribes were paid 31 times over a period of two years and six months, amounting to a total of JPY28 million. • The bribes undermined public trust in the fairness of the officials involved in the operation of the Tokyo Olympics and Paralympics, a sporting event that attracted worldwide attention and is consid - ered to be of particular national importance. In addition, the former executive officer of the adver - tising company was convicted by the Tokyo District Court on 12 March 2024. He was sentenced to two years in prison, with a four-year suspended sentence, for the following reasons. • The amount of the bribe provided by the defend - ant, approximately JPY6.5 million, was substantial. • The defendant’s crime distorted the process of deciding Olympic sponsors and undermined confi - dence in the operation of the Tokyo Olympics and Paralympics. Some defendants are still undergoing first-instance trials or have appealed. Therefore, it is necessary to continue monitoring the situation in multiple court cases and await the outcome of this scandal. Bribery of Foreign Public Officials Overview of the laws and regulations on bribery of foreign public officials In 1997, Japan ratified the OECD Convention on Combating Bribery of Foreign Public Officials in Inter - national Business Transactions. In 1998, the UCPA was amended to recognise bribery of foreign public officials as a crime. Japan is also a signatory to the United Nations Convention Against Corruption, which includes provisions requiring legal action against the acceptance of bribes by domestic public officials and bribery of domestic and foreign officials.
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