JAPAN Trends and Developments Contributed by: Takashi Koyama and Tomomi Fukutomi, Oh-Ebashi LPC & Partners
market prohibitions (such as restrictions on issuance by specified sovereign and quasi-sovereign actors). MOFA has frequently updated its consolidated sanc - tion lists since 2022. In December 2022, Japan implemented the G7 price cap on Russian crude oil and petroleum products, prohibiting maritime services and payments above the cap. This measure was operationalised through the FEFTA’s payment permission regime and co-ordi - nated METI/MOF Notices. On 12 September 2025, Japan lowered the price cap from USD60 per barrel to USD47.6 per barrel. METI provides detailed guidance on its Russia sanc - tions page, including G7/GECC materials enumerating “Common High-Priority Items” which are prohibited from export. METI has also published resources high - lighting the risks of evading sanctions and the need for countermeasures, including red flags and case stud - ies of circumvention through third-country exports. Japan also imposes similar sanctions on Belarus, and imposes trade restrictions on goods originating in Ukraine (limited to those originating in the Autono - mous Republic of Crimea or the city of Sevastopol since 2014 as well as in the self-proclaimed Donetsk People’s Republic or the Luhansk People’s Republic since 2022) aligned with coalition-based measures. Recent enforcement examples On 16 December 2025, METI issued a formal warning to RED BARON Co, Ltd, for exporting motorcycles to Russia without obtaining the required ministerial approval between 2022 and 2024. METI directed the company to strengthen export control compliance, clarify internal procedures, and implement measures to prevent recurrence. Under Japan’s sanctions on Russia pursuant to the FEFTA, exporting motorcycles valued at over JPY600,000 to Russia requires prior approval from the Minister for Economy, Trade and Industry. RED BARON Co, Ltd, circumvented this requirement by routing exports through third countries such as South Korea, triggering the above warning action. In addition to the above, unauthorised export of per - sonal watercrafts and used motorcycles to Russia
led to convictions in 2024 and the same for passen - ger cars in 2025. In the former case, METI issued an order to the company concerned and its representa - tive director (a Russian national) prohibiting the export of goods for a period of one year and prohibiting its representative director from assuming any executive position in the relevant company for the same period of the above prohibition. METI has also highlighted further cases in its compli - ance guidance materials to illustrate common pitfalls and the importance of strict adherence to the FEFTA requirements, as outlined below. • Case 1 : transshipment to Russia via a third country – Exports to Russia are restricted under Japan’s sanctions regime. In this case, regulated goods were shipped to Russia via a third country. The exporter mistakenly believed that sanctions only applied to direct exports to Russia and failed to confirm the interpretation with METI. Under the FEFTA, if the goods are ultimately destined for Russia, the destination is considered Russia – even if routed through another country. Exporting to a third country for onward shipment constitutes a transshipment export, which violates the relevant sanctions under the FEFTA. • Case 2 : misinterpretation of luxury goods threshold for passenger vehicles – An exporter was aware that passenger vehicles and similar luxury goods exceeding JPY6 million per unit were restricted under Russia sanctions, but misinterpreted the threshold as the purchase price rather than the export value. The exporter proceeded with a direct shipment to Russia. METI clarified that the “amount per unit” for luxury goods sanctions was calculated based on the total value under the export contract divided by the number of units, or, if different, the FOB price at the Japanese port of export at the time of shipment. Passenger cars and goods vehicles with engine displacement exceed - ing 1,900 cc, hybrid engine passenger cars and similar vehicles are subject to these measures.
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