JAPAN Trends and Developments Contributed by: Keiji Tonomura, Shu Sasaki, Kazuyuki Ohno and Otoki Shimizu, Nagashima Ohno & Tsunematsu
and implementation of detailed mechanisms to address safeguarding funds received from users in a manner different from existing deposit insur - ance mechanisms. Based on these considerations, the 2025 Report concluded that it is unnecessary to permit the issuance of electronic payment instruments by banks in the near future. Authorised Self-Regulatory Organisation for Electronic Payment Instruments Services - JVCEA On 25 October 2024, the JFSA approved the Japan Virtual and Crypto-Assets Exchange Association (JVCEA) as a certified association for payment service providers for the electronic payment instruments services in accordance with Article 87 of the PSA. As mentioned above, it is assumed that stable - coins can be transferred and distributed among users in a rolling manner, and there is a regula - tory licence for electronic payment instruments services (Article 62-3, Paragraph 2, Article 10 of the PSA). Stablecoin is treated as an “electronic payment instrument” under the PSA, and the related ser - vices cover the following activities as a business: • purchase and sale of an electronic payment instrument or exchange with another elec - tronic payment instrument; • intermediary, brokerage or agency services for the activities set forth in the preceding item; or • management of electronic payment instru - ments on behalf of another person (subject to certain exemptions).
In other words, registration as an electronic pay - ment instrument service provider is required for the purposes of engaging in business such as purchasing, selling and managing stablecoin, which is an electronic payment instrument. In order to obtain registration as an electronic pay - ment instrument service provider, entities must satisfy certain requirements under the PSA and JFSA guidelines, particularly in the areas of user protection, AML/CFT, and system risk manage - ment. Additionally, it is important for electronic pay - ment instrument service providers to comply with the self-regulatory rules of the certified association for payment service providers under the PSA. As mentioned above, the JFSA has accredited the JVCEA as a certified association for payment service providers for the electronic payment instrument service. To register as an electronic payment instrument service provider, entities must either join the JVCEA or establish internal rules equivalent to the JVCEA’s articles of incorporation or other rules and establish systems to ensure compli - ance (Article 62-6, Paragraph 1, Item 6 of the PSA). However, there are certain important rules not expressly stated in the PSA or JFSA guide - lines, such as the requirement that stablecoins must have undergone a preliminary review by the JVCEA before an electronic payment instru - ment service provider can offer stablecoins as a means of electronic payment. As of the date of this article, no entity has obtained registration as an electronic payment instrument service provider. However, with JVCEA’s recognition as a self-regulatory organi - sation, the registration process is expected to proceed more smoothly in the future. Regulatory preparations are steadily being made not only for
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