Sanctions 2026

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

North Korea: UNSC-based and own autonomous sanction measures For North Korea, Japan is implementing both UNSC- driven sanctions and Japan’s own autonomous meas - ures. UNSC - based measures Japan enforces all measures mandated by UNSC resolutions, including: • asset freezes – individuals and entities designated by the Security Council or its sanctions committee; • export bans – all arms, luxury goods, aviation fuel, new helicopters and vessels, crude oil (annual ceil - ing: 4 million barrels or 525,000 tonnes), petroleum products (annual ceiling: 500,000 barrels), machin - ery, electrical equipment, transport equipment, iron and steel, base metals, and more; • import bans – all arms, specific natural resources (coal, iron, iron ore, copper, nickel, silver, zinc, lead and lead ore), marine products (including fishing rights), textiles, agricultural products, machinery, electrical equipment, earth and stone, timber, ves - sels, etc; and • other restrictions – personnel exchanges, port calls by North Korean vessels, and related activities. Japan ’ s own autonomous measures Beyond UNSC obligations, Japan imposes stricter controls: • export ban – since 2009, the export of all items to North Korea (including those from a third coun - try) requires prior approval from the Minister for Economy, Trade and Industry; and • import ban – since 2006, the import of all items from North Korea requires prior approval from the Minister for Economy, Trade and Industry. The approval for the above items is not granted except in rare cases of limited exceptions. Further, entry into Japan by North Korean nationals is gen - erally prohibited. All North Korean vessels and any foreign vessels that called at a North Korean port are prohibited from entering Japan. The reporting thresh - old for carrying means of payment to North Korea has been lowered from the equivalent of over JPY1 million to JPY100,000.

These measures have been repeatedly extended, most recently in April 2025, when Japan decided to continue them until 13 April 2027. Recent enforcement example On 15 March 2024, METI issued a formal warning to an individual who imported alcoholic beverages that originated in North Korea as hand luggage without obtaining the required ministerial approval. This vio - lated Japan’s blanket import ban in place since 2006. METI’s press release reiterated that the ban applies to all goods of North Korean origin or shipped therefrom, with no personal effects exception for hand-carried items in the absence of prior approval. Furthermore, the unauthorised import of freshwater clams from North Korea in violation of trade sanctions led to a conviction in 2025. In addition, on 24 March 2026, METI issued an order against an individual who had imported freshwater clams originating from North Korea via China or South Korea without obtaining approval from the Minister for Economy, Trade and Industry. The order (i) suspended the individual’s import activities for a period of three years and (ii) prohibited the individual from assum - ing any executive position in a company engaged in import operations for the same period. Japanese authorities have previously taken enforcement action against the smuggling of clams originating from North Korea, which is among the more common types of sanctions violations in Japan. Furthermore, METI has introduced other enforcement examples in its published materials, including the fol - lowing. • Case 1 – An order for daily necessities was received from an acquaintance residing in North Korea, declared to customs as being exported to China, and subsequently re-exported to North Korea. • Case 2 – At a business meeting held in China, the purchase of North Korean seafood products was agreed upon after being introduced by a Chinese company, and the goods were subsequently imported into Japan via China.

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