JAPAN Law and Practice Contributed by: Eiji Kobayashi, Masaki Fujita, Suguru Yokoi and Ryusuke Bushimata, Anderson Mori & Tomotsune
Anderson Mori & Tomotsune Otemachi Park Building 1-1-1 Otemachi Chiyoda-ku Tokyo 100-8136 Japan Tel: +81 3 6775 1074 Fax: +81 3 6775 2074 Email: eiji.kobayashi_grp@amt-law.com Web: www.amt-law.com/en/
1. Trends and Overview 1.1 Sanctions Market No significant change in the sanctions sector has been observed compared to 12 months ago. Over the last 12 months, the list of designated indi - viduals and entities subject to financial sanctions has been expanded several times, targeting Russia for its continuing invasion of Ukraine, though less frequent - ly than before. As for North Korea, the total ban on imports and exports originally implemented in 2006 and 2009, respectively, was extended once again for an additional two years in April 2025. 1.2 Key Trends The key trend regarding the sanctions regime remains the close attention paid by the Japanese authorities to any efforts made to evade the sanctions imposed on Russia. Particularly, the authorities have been concerned about illegal exports from Japan to Russia through a third country or third party. In the fall of 2023, the authorities officially emphasised that such exports can constitute breaches of sanctions, and encour - aged businesses to analyse parties involved in their transactions, and for their transaction schemes to be carefully scrutinised before being entered into. If goods exported to a third country are unintentionally supplied to Russia, such due diligence measures may release the exporter from liabilities for illegal export thereto. Further, in December 2024, the Ministry of Economy, Trade and Industry (METI) uploaded on its
website an explanatory document, and an explanatory video therefor, which contained warnings against ille - gal exports via third countries and red flags for trans - actions evading sanctions. To prevent illegal exports to Russia via third countries or third parties, since 2024 Japan has been desig - nating certain non-Russian entities (companies in the UAE, Turkey, Syria, Armenia, China, India, Thailand, Kazakhstan, Kyrgyz Republic and Uzbekistan) subject to export bans. Japan also designated certain ship - ping companies, including Cyprus-based entities, subject to restrictions on payments, which indirectly makes it impermissible for a Japanese resident to pur - chase their transportation services. 1.3 Key Industries Since the spring of 2022, Japan has been intensify - ing its sanctions against Russia, which has affected Russia-related business conducted by Japanese companies – particularly those manufacturers that had operations in Russia or exported products to the Russian market. 1.4 Overview 1.4.1 Types of Sanctions Japan may implement the following types of sanctions under the current legislation. Financial Sanctions Financial sanctions include restrictions on the mak - ing and receipt of payments; the execution, change and termination of transactions on deposits, trusts
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