JAPAN Law and Practice Contributed by: Eiji Kobayashi, Masaki Fujita, Suguru Yokoi and Ryusuke Bushimata, Anderson Mori & Tomotsune
Trade Sanctions Export or import bans apply to those who export goods from or import goods into Japan, irrespective of their residency. As for the provision of technologies, everyone must comply with sanctions when providing technologies from Japan. In addition, all Japanese residents must comply with sanctions when providing technologies to a non-resident or a Japanese resident connected with a designated country. Restrictions on the provision of services apply to Jap - anese residents. 1.4.3 Domestic and/or Supranational Measures Japanese sanctions may be imposed either to comply with international obligations – for example, resolu - tions adopted by the United Nations (eg, in relation to North Korea, Iran, the Democratic Republic of Congo, Somalia, Yemen and other countries) – or to co-oper - ate with other countries or international communities (eg, in relation to Russia and Syria) or maintain the peace and security of Japan (eg, in relation to North Korea). The primary regulators for Japanese sanctions activity are the Ministry of Foreign Affairs (MOFA), the MOF, and METI. 2.2 Enforcement 2.2.1 Enforcement Responsibilities The MOF implements and enforces primarily finan - cial sanctions, but also restrictions on the provision of some services, while METI implements and enforces primarily trade sanctions, but also some financial sanctions. 2.2.2 Breaching Sanctions Criminal Offence For violations of financial and trade sanctions, criminal liabilities may be imposed. For violations of export or import restrictions, the potential penalties to an indi - vidual offender are imprisonment for up to five years 2. Overview of Regulatory Field 2.1 Primary Regulators
or a fine of up to JPY10 million (but no more than five times the value of a transaction violating the sanc - tions), or both. In addition, a company for which the offender works may also be subject to a fine of up to JPY500 million, but no more than five times the value of a transaction in breach of the sanctions. Administrative Liabilities For violations of export or import restrictions, METI may ban exports or imports for up to three years or prohibit an individual offender from engaging in the activities of a company in a specified business as a director or an officer for up to three years. 2.2.3 Civil Enforcement Action Generally, authorities make public only a small num - ber of administrative enforcement actions each year, primarily related to violations of export or import bans. In May 2025, METI announced an administrative penalty in connection with the unauthorised export of motorcycles and other goods to Russia via South Korea. This was prosecuted as a criminal case, as outlined in 2.2.4 Criminal Enforcement Action . As an administrative penalty, METI imposed a one-year ban on the Japanese company and its CEO, prohibiting them from exporting the sanctioned goods to any region. In March 2024, METI issued a warning to an individual who had imported alcohol originating in North Korea via a hand carry-on in breach of sanctions in 2019, requesting compliance with import regulations. 2.2.4 Criminal Enforcement Action By June 2025, several criminal enforcement actions related to sanctions had been made publicly available in 2024 and 2025, while none were disclosed in 2022 or 2023. In April 2025, the former CEO of a Japanese marine products import company received a one-and-a-half year prison sentence, suspended for three years, for the unauthorised import of seafood from North Korea. As part of the company’s operations, he imported 18,000 kg of clams originating in North Korea, with a declared value of JPY3.4 million, from a port in South Korea in January 2020. He falsely declared to customs
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