Sanctions 2025

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

Trade Sanctions Typical trade sanctions include restrictions on the import and export of goods, intermediary trading, and the provision of technologies and certain services. Trade sanctions are in place primarily in relation to North Korea and Russia as of 20 June 2025. In the case of sanctions against Russia, price caps are set on Russian oil and oil products, and certain services in relation to the trading of Russian oil and oil products are prohibited. Restrictive Border Measures Travel bans and entry bans of vessels and aircrafts are also possible. As sanctions measures, Japan has blocked the entry of North Korean nationals, North Korean vessels and any vessels that have called at North Korean ports, and the entry of designated persons involved in or relating to Russia’s invasion of Ukraine. 1.4.2 Scope of Sanctions General Principles The key criteria for determining the application of Japanese sanctions are Japanese residency and links with Japan. The current sanctions legislation does not adopt extraterritorial application. Under the Foreign Exchange Act, which regulates financial and trade sanctions, a Japanese resident is defined as a natural person with a domicile or resi - dence in Japan or a corporation whose principal office is in Japan. A branch office, local office, or other such office of a non-resident in Japan is deemed to be a Japanese resident, even if the non-resident’s principal office is located in a foreign state. Financial Sanctions Generally, financial sanctions apply to a Japanese resident. Restrictions on payments apply also to a designated non-resident when payments are made from Japan.

and loans; outward and inward investments; and the issuing, obtaining and transferring of securities. Under the sanctions regime, modes of payment include settlements by set-off and payments in sub - stitution. Under Japanese law, there is no measure expressly called an “asset freeze”, but in practice, restrictions regarding payments and transactions on deposits, trusts and loans are referred to as “asset freeze” measures. In particular, the making of payments and the con - ducting of transactions involving deposits, trusts and loans to designated individuals and entities associ - ated with various countries, including North Korea, Russia, Belarus and Iran, as well as terrorist organisa - tions, have been restricted. Restrictions on the receipt of payments apply only in limited cases as of 20 June 2025. Investment bans apply to inward investments by Ira - nian persons in a Japanese company in the indus - try of nuclear technology, and outward investments by Japanese residents in a Russia-related company. The scope of outward investments in a Russia-relat - ed company under the sanctions regime includes the acquiring of a share of 10% or more of a non-resident (a Russian or non-Russian company) in relation to a Russian business, the increasing of the share of a non-resident of which it already holds 10% or more in relation to a Russian business, and the provision of a long-term loan to a non-resident of which it holds a share of 10% or more in relation to Russian busi - nesses. As part of financial sanctions, financial institutions are obliged to check and make sure that payment opera - tions will not violate the sanctions regulations under the Foreign Exchange and Foreign Trade Act (the “Foreign Exchange Act”). If the Ministry of Finance (MOF) finds that a bank does not fulfil this obligation or might fail to, it is entitled to order the bank to take appropriate actions.

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