JAPAN Trends and Developments Contributed by: Masayuki Atsumi and Yuhei Sakao, Miura & Partners
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Anti-Corruption in Japan: An Introduction In February 2024, the Ministry of Economy, Trade and Industry (METI) published the amend - ed Guidelines for the Prevention of Bribery of Foreign Public Officials (the “Guidelines”), as described below. This is the first amendment since May 2021. To understand the reasons for and content of the amendment of the Guide - lines, it is necessary to learn about the trends and development of anti-corruption efforts in Japan. Japan is recognised as a country where bribery and other forms of corruption are relatively rare. In fact, according to the Corruption Perceptions Index 2023, which is published by Transparency International, Japan is the 16th cleanest country among 180 countries in the world (ranking above the USA). However, Japan still experiences many bribery cases involving politicians or public officials that are uncovered and widely reported every year. The public has paid close attention to the many arrests that have been widely reported both in Japan and abroad, including of executives of famous companies in bribery cases surrounding the Tokyo Olympics and Paralympics. In 2024, a former executive officer of an advertising com -
pany was convicted of bribery (Tokyo District Court decision on 12 March 2024). In addition, as described below, the OECD Work - ing Group on Bribery (WGB) has pointed out the low number of cases involving bribery of foreign public officials in Japan, and has made 17 rec - ommendations to the Japanese government to improve its enforcement. In response, METI held discussions related to the laws and regulations on the bribery of foreign officials, which led to the amendment of the Unfair Competition Pre - vention Act (UCPA). Bribery of both domestic and foreign public offi - cials has received a lot of attention in society. Therefore, employees and executives in all com - panies need to properly understand and com - ply with anti-bribery and anti-corruption laws and regulations in Japan and take appropriate measures to prevent corruption. To help in this regard, this article introduces the latest trends and developments in anti-corruption regulation in Japan. Bribery of domestic public officials Overview of the laws and regulations on the brib- ery of domestic public officials
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