Sanctions 2025

JAPAN Law and Practice Contributed by: Eiji Kobayashi, Masaki Fujita, Suguru Yokoi and Ryusuke Bushimata, Anderson Mori & Tomotsune

Anderson Mori & Tomotsune is a full-service law firm with around 700 professionals that is best known for serving overseas companies doing business in Japan since the early 1950s. It is proud of its long tradition of serving the international business and legal com - munities, and of its reputation as one of the largest full-service law firms in Japan. The firm’s economic securities and international trade practice group consists of approximately 50 lawyers and provides

advice in the areas of sanctions, international trade law and economic securities. The firm’s strength lies in its team of specialists who are well-versed in the practicalities of various countries, including Japan, Russia, CIS, the United States, and China. The firm’s main office in Tokyo is supported by offices in Osaka, Nagoya, Beijing, Shanghai, Singapore, Ho Chi Minh City, Bangkok, Jakarta, Hong Kong, London, Hanoi and Brussels.

Authors

Eiji Kobayashi is a partner at Anderson Mori & Tomotsune. He has been involved in a broad range of legal services in connection with large-scale projects, including real estate development, renewable

Masaki Fujita is a partner at Anderson Mori & Tomotsune and is based in the Tokyo office. Masaki has been a secondee at one of Japan’s largest international trading companies and is well experienced in

energies projects, fund investments, project financing transactions and dispute resolution related thereto, advising clients (domestic and foreign) such as investors, developers, constructors and manufacturers in these matters. His overseas practice experience includes work in a number of Russia-related matters, including joint venture transactions and investment transactions with Russian companies, as well as in sanctions-related matters.

international trade matters. He has detailed knowledge of the economic sanctions imposed by Japan, the US, the EU and the UK, and is frequently retained by large Japanese corporations to advise them on the nature of the economic sanctions imposed by numerous countries. Masaki also advises clients on a wide range of regulatory, compliance, investigatory and enforcement matters related to international trade and national security, including trade controls, clearances for foreign investments and industrial security issues. Ryusuke Bushimata is a senior associate at Anderson Mori & Tomotsune. He specialises in investment screening, financial sanctions and export controls, drawing on his experience as a director at the International Bureau of the Ministry of Finance. During his tenure with the Ministry, Ryusuke provided legal advice to the Japanese government, supporting the establishment of sanction policies and legislation. He has liaised with government agencies at both the domestic and international level, including CFIUS and OFAC.

Suguru Yokoi is a partner at Anderson Mori & Tomotsune (AMT) and a registered foreign lawyer at Nakamura & Associates, AMT’s

associated firm in Hong Kong. He is also a former representative of AMT’s Beijing and Shanghai offices. Suguru has extensive experience in advising private companies and government agencies on international trade law, import and export control, sanctions and business and human rights. In particular, he specialises in matters relating to Japan and the Greater China region, based on his on-the-ground experience and in-depth knowledge of these areas.

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