Sanctions 2026

JAPAN Trends and Developments Contributed by: Takashi Koyama and Tomomi Fukutomi, Oh-Ebashi LPC & Partners

UNSC - based sanctions implemented by Japan As of June 2026, the following Japanese sanctions to implement UNSC resolutions are currently in place: Taliban (2001), Terrorists (UNSC Resolution 1373 framework, 2001), Iraq (former regime, 2003), Demo - cratic Republic of the Congo (2005), Sudan (2006), North Korea (initial measures in 2006; expanded in 2009 and onwards), Somalia (2010), Libya (Gaddafi regime, 2011), Central African Republic (2014), Yemen (2014), South Sudan (2015), Iran (reactivated in 2025 through the UNSC “snap-back” mechanism), Mali (2020) and Haiti (2022). Japan ’ s coalition - based and autonomous sanctions In addition to implementing UNSC resolutions, Japan exercises flexibility to adopt sanctions under coalition agreements with like-minded states such as the EU and the USA, and to impose autonomous measures. Key examples of coalition-based sanctions include those in respect of former Yugoslav President Slo - bodan Milošević and related persons (2001), North Korea (2009 and 2013), former Syrian President Al Asad and related persons (2011), the Crimea Annex - ation/Eastern Ukraine destabilisation (2014), Rus - sia (2022), Belarus (2022) and Israeli settlers (2024). Japan also enforces autonomous measures, notably comprehensive import and export bans against North Korea (2006 and 2009). MOF provides a list of individuals and entities subject to asset freezes and other measures under the afore - mentioned sanctions, as noted above. Enforcement Mechanisms Permission and approval mechanism under the FEFTA Payments Any payment subject to sanctions measures requires prior permission, mainly from the Minister for Finance. In practice, Japanese banks must verify the purpose of the transaction, review counterparties and benefi - cial owners, and request supporting documentation to ensure compliance with payment regulations, includ - ing those under the FEFTA. Capital transactions Activities such as deposits, trusts, loans and the issu - ance or acquisition of securities that fall under sanc -

smooth implementation, both MOF and METI publish guidance materials for financial institutions and com - panies. Japan’s Unique Characteristics in Sanctions Policy Single statute implementation of multiple measures Japan’s sanctions regime is distinctive because it consolidates control over payments, capital transac - tions, and trade in goods, services and technology within a single statute – the FEFTA. This structure ena - bles Japan to apply sanctions measures to specific transaction types more consistently and efficiently. Authorities can freeze or restrict payments, approve or halt capital transactions, and ban trade in goods, services and technology – all under one coherent legal framework. By contrast, the USA provides separate statutes such as the International Emergency Economic Powers Act (IEEPA) and Trading with the Enemy Act, operation - alised primarily through the Office of Foreign Assets Control (OFAC). US sanctions are often implemented via executive orders and regulations targeting specific sectors or actors. The EU adopts Council Decisions and Regulations on sanctions under the Common Foreign and Security Policy (CFSP). These measures are directly applicable across member states but require national implemen - tation legislation for penalties. Multi-track approaches beyond UNSC resolutions Japan’s sanctions framework is not limited to imple - menting UNSC resolutions. It also provides flexibil - ity to adopt measures under coalition-based com - mitments among like-minded states and to impose autonomous sanctions. This adaptability enables Japan to participate in, for instance, G7-led initia - tives, such as the co-ordinated price cap on Russian crude oil and petroleum products. These measures are enforced through the FEFTA’s permission/approval requirements and payment restrictions, ensuring that Japan can operationalise coalition-based commit - ments within its domestic legal system.

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