Sanctions 2025

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

6.2 Enforcement No enforcement case has been reported in the pub - licly available legal sources where the enforcement of judgments or arbitration awards has been litigated in relation to the sanctions as of 20 June 2025.

Sanctions Against North Korea No goods may be exported to North Korea from Japan, except where medicine, foods and other goods are donated to international organisations in North Korea, and where personal goods are exported for personal use. No goods originating from or loaded within the bor - ders of North Korea may be imported into Japan. In addition, a Japanese resident is prohibited from selling, purchasing, lending, leasing or donating any goods originating from, loaded within the borders of or delivered to North Korea when such goods are trans - ferred between destinations outside Japan (intermedi - ary trading). Sanctions Against Russia and Ukraine Bans on exports to Russia apply to a wide range of goods, including high-tech goods, goods that can contribute to the strengthening of the Russian military and its industries and luxury goods. Exports to certain designated entities are banned for all goods. As for imports, it is prohibited to import alcohol, wood and forestry equipment, gold and non-industrial dia - monds originating from or loaded within the borders of Russia, and to import oil and oil products originating from Russia that are traded at prices exceeding the specified limit. Intermediary trading is also prohibited for Russian oil and oil products that are traded at prices exceeding the specified limit. With regard to conflict zones within Ukraine, no goods may be exported to such zones from Japan, and no goods originating from these zones may be imported to Japan. 6. Civil Litigation and Arbitration 6.1 Force Majeure No civil litigation case has been reported in the pub - licly available legal sources regarding the performance of contractual obligations under the sanctions as of 20 June 2025.

7. Designation, Compliance and Circumvention 7.1 Executive Body

MOFA designates individuals or entities subject to restrictions on payments and transactions on depos - its, trusts and loans, and to export bans. 7.2 Scope of Designation The Foreign Exchange Act does not provide a gen - eral rule on the indirect designation of a person being owned or controlled by a directly designated person. However, in the case of sanctions against Russia, MOFA has determined that it will apply restrictions on payments and transactions on deposits, trusts and loans to designated entities and their subsidiar - ies where 50% or more of the shareholding of such subsidiaries is held by designated Russian and Bela - russian entities. In the case of export bans in relation to Russia, such a rule on indirect designation does not apply. 7.3 Circumvention 7.3.1 Prohibiting Provisions There is no direct provision prohibiting the circumven - tion of sanctions. However, the authorities pay close attention to these matters, particularly in relation to the present sanc - tions against Russia. Thus, the authorities have issued a warning that an export to a third country or third party intending to deliver goods to Russia can con - stitute a breach of sanctions. Careful consideration is required when exporting goods from Japan to a third party located in a third country that manufactures products using goods from Japan and then exports such products to Russia. Depending on the situation, the export of goods from Japan to a third country can be regarded as an export to Russia and can thus be in breach of the sanctions.

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