Financial institutions that enter into derivative contracts carry out verification at the time of transaction, reporting of suspicious transactions, and screening of payments and transactions against sanctioned parties. Compliance staff check this work against the legal obligations, and these rules are the basis for that check.

What the rules require

Anti-money laundering and countering the financing of terrorism (AML/CFT) and economic sanctions both impose obligations on financial institutions, but their purposes and the laws behind them differ.

AML/CFT rules aim to prevent the transfer of funds obtained through crime and the financing of terrorism. In Japan, the Act on Prevention of Transfer of Criminal Proceeds requires specified business operators, including financial instruments business operators, to take measures such as verifying their clients, keeping transaction records, and reporting suspicious transactions1.

Economic sanctions work through the Foreign Exchange and Foreign Trade Act, which imposes an obligation to obtain permission for payments and transactions. The competent minister can impose this obligation when it is necessary to faithfully observe an international commitment such as a treaty, when it is particularly necessary to contribute to international efforts for international peace, or when the Cabinet has decided to take a countermeasure2. Asset freezes and similar measures against Taliban-related persons, terrorists, and others are carried out by designating the targets and making payments to them, and capital transactions such as deposit contracts with them, subject to permission, which is then denied3.

The Financial Action Task Force (FATF) sets the international standard. FATF was established at the Arche Summit in July 1989, mainly by the major advanced countries, to strengthen international cooperation against money laundering linked to drug crimes. In 1990 it produced the "40 Recommendations" as the standard for the measures each country should take. It has since widened its mandate to measures against terrorist financing and proliferation financing (financing the spread of weapons of mass destruction). Members evaluate one another both on how far they have put the 40 Recommendations in place and on how effective the measures are, using 11 effectiveness criteria4.

The risk-based approach means that financial institutions identify and assess their own risks and take measures in proportion to them. It is Recommendation 1 in the FATF recommendations and a basic principle that runs through all of them5.

Derivatives fall under both sets of rules. Entering into a contract for an OTC derivative transaction is a transaction that requires verification at the time of transaction (a specified transaction) under the Act on Prevention of Transfer of Criminal Proceeds. The creation of claims under derivative transactions between residents and non-residents is a capital transaction under the Foreign Exchange and Foreign Trade Act. The practice of KYC with clients is covered in KYC and Credit Review.

Provision What it provides Authority
Act on Prevention of Transfer of Criminal Proceeds Verification at the time of transaction by specified business operators, keeping of verification records and transaction records, reporting of suspicious transactions The administrative agency that supervises the specified business operators. Report information is gathered by the National Public Safety Commission6
Foreign Exchange and Foreign Trade Act Payments, capital transactions, and other dealings can be made subject to permission in order to carry out treaties or for international peace. Banks, etc. have a duty to confirm, and foreign exchange transaction handlers have compliance standards The competent minister for payments, the Minister of Finance for capital transactions2
FSA guidelines A document in which the FSA sets out the "matters requiring action" for financial institutions' AML/CFT controls. It covers the specified business operators under the FSA's jurisdiction Financial Services Agency7
Ministry of Finance guidelines A document setting out the controls that foreign exchange transaction handlers need in order to comply with the economic sanctions obligations in the foreign exchange laws and regulations Ministry of Finance, International Bureau8

The provisions were checked against the versions published on e-Gov Laws and Regulations Search as of October 3, 2026.

The FSA says it will take administrative action under the laws, such as requiring reports or issuing business improvement orders, taking the supervisory guidelines for each type of business into account. This applies when measures listed as matters requiring action in its guidelines are inadequate and there is a problem with the controls7. The Act on Prevention of Transfer of Criminal Proceeds also has a provision allowing the administrative agency to enter the premises of a specified business operator and inspect its books and documents, and a provision allowing it to order measures to correct a violation9.

Transactions and parties covered

The Act on Prevention of Transfer of Criminal Proceeds

The obligations in the Act fall on specified business operators, which include financial instruments business operators under the Financial Instruments and Exchange Act (FIEA)10. The FSA guidelines cover the specified business operators under the FSA's jurisdiction. Financial institutions licensed or registered under the Banking Act, the Insurance Business Act, the FIEA, and other laws are also subject to the Foreign Exchange and Foreign Trade Act as "banks, etc." and "financial institutions, etc."11.

The transactions that require verification at the time of transaction (specified transactions) are set by an appended table to the Act and by a Cabinet Order. The Cabinet Order lists the conclusion of contracts to carry out certain acts under the FIEA, and contracts for OTC derivative transactions fall within this. However, the order excludes from specified transactions those transactions for which a competent ministerial ordinance allows simplified customer due diligence, based on the degree of risk shown in the report assessing the risk of transfer of criminal proceeds. As an exception to this exclusion, transactions that need special attention, such as suspicious transactions and others specified by competent ministerial ordinance, are specified transactions even where they would otherwise be subject to simplified customer due diligence12.

The Foreign Exchange and Foreign Trade Act

The obligation to obtain permission under the Foreign Exchange and Foreign Trade Act is imposed on residents and non-residents, not only on financial institutions13. Capital transactions include transactions between a resident and a non-resident that give rise to claims under a derivative contract. Transactions between residents are capital transactions only in limited cases, such as where a claim payable in foreign currency arises14. The derivative contracts here (financial indicator futures contracts) are contracts relating to market derivative transactions, OTC derivative transactions, and the like under the FIEA, excluding those specified by Cabinet Order15. When an event arises that would obstruct the carrying out of a treaty, for example, the Minister of Finance can impose an obligation to obtain permission for capital transactions, as provided by Cabinet Order16. In addition, a payment from Japan to a foreign country can also be subject to permission, and the duty of banks, etc. to confirm also relates to payments, so the payment side is checked separately217.

Financial institutions also have separate obligations. Before carrying out a funds transfer relating to a client's payment, a bank, etc. must confirm that the payment is not one that requires permission or, if it is, that permission has been obtained17. For certain financial institutions, the competent minister sets compliance standards to establish controls for confirming whether a transaction requires permission. The parties covered are specified by Cabinet Order, and a party so covered (a foreign exchange transaction handler) is obliged to conduct transactions in accordance with those standards18.

Deciding whether a capital transaction is subject to a permission duty, with examples

Figure 1 sets out, in the order of the conditions above, how to tell whether a transaction under a derivative contract is subject to a permission duty (the obligation to obtain permission) for capital transactions under the Foreign Exchange and Foreign Trade Act. Payments are not drawn in this figure.

YesNoIs it based on a FIEAderivative contract?Not coveredin this figureYesNoResident andnon-resident, orforeign-currency claimbetween residents?Not coveredin this figureYesNoHas the Minister ofFinance imposed apermission duty?No permissiondutyGenerally atransactionsubject to apermission duty
Figure 1Is a transaction under a derivative contract subject to a permission duty for capital transactions?
Figure description

The figure shows three questions in order. If the first or second is answered no, the transaction is not covered in this figure. If the third is answered no, there is no permission duty. The figure does not check whether such a duty has actually been imposed under the third question. If every answer is yes, the transaction is generally one subject to a permission duty. Two conditions the figure does not show are checked separately in the earlier explanation of the Foreign Exchange and Foreign Trade Act: the cases covered by "the like" for transactions between residents, and the payment side from Japan to a foreign country.

Consider a hypothetical example in which Bank Y, a resident bank, enters into a contract for an OTC derivative transaction under the FIEA (not one excluded by Cabinet Order). Whether a permission duty has actually been imposed is taken as a premise, and no other conditions are assumed.

Example Conditions Applying the conditions in the text
1 Bank Y enters into a contract with a non-resident business, and a claim arises. A permission duty is taken to have been imposed on that capital transaction All the questions are answered yes, so it is generally a transaction subject to a permission duty
2 Bank Y enters into a contract with a resident business, and the only claim that arises is one payable in yen. The contract's financial indicator is not in a foreign currency The second question is answered no (the transaction is between residents and no foreign-currency claim arises), so it is not covered in this figure
3 The conditions are the same as in example 1, but no permission duty has been imposed on that capital transaction The third question is answered no, so there is no permission duty

That the contract in example 2 does not relate to a foreign-currency financial indicator is a condition the figure does not show. It is checked in the section "The Foreign Exchange and Foreign Trade Act".

What is required

The Act on Prevention of Transfer of Criminal Proceeds

When a specified business operator carries out a specified transaction, it carries out verification at the time of transaction (confirming identifying information, the purpose of the transaction, the nature of a corporation's business, and the persons who can effectively control the management of the corporation's business, namely its beneficial owners)19. Three points add the legal position.

  • The measures vary with risk. For transactions where impersonation is suspected, or transactions with clients residing in specified countries and the like where the systems are inadequate, the operator also confirms the client's assets and income if the transaction moves property above an amount set by Cabinet Order20. Transactions with clients whose verification records are kept have an exception. What this exception disapplies is the ordinary verification at the time of transaction; transactions where impersonation is suspected and the like, mentioned above, require separate confirmation21.
  • Separately from verification at the time of transaction, when a transaction is carried out the operator immediately prepares a transaction record, except for small transactions and the like, and keeps it for seven years from the date of the transaction22.
  • Whether a transaction is suspicious is judged by checking it against the items set by competent ministerial ordinance. The judgment takes into account the results of verification at the time of transaction, the manner of the transaction, and other circumstances. It also takes into account the content of the report assessing the risk of transfer of criminal proceeds, which is published every year. The operator may not disclose to the client or others that it is about to file a report or has filed one2324.

Figure 2 lays out the sequence from verification at the time of transaction to the report, from the side of the specified business operator.

Specified business operatorPublic Safety Comm.SuspiciousEnter into anOTC derivativecontractVerification at thetime of transaction(identifying info, etc.)Prepare atransaction record,keep it 7 yearsJudge whethersuspiciousFile a reportReport informationis gathered
Figure 2From verification at the time of transaction to the suspicious transaction report
Figure description

A specified business operator carries out verification at the time of transaction when it conducts a specified transaction, such as a contract for an OTC derivative transaction. It prepares a transaction record, except for small transactions and the like, and keeps it for seven years from the date of the transaction. Taking into account the results of verification and other circumstances, it judges whether the transaction is suspicious, and files a report if it is. The preparation and keeping of the transaction record and the judgment of suspicion are separate obligations in the provisions, and the provisions do not fix their order relative to each other. The figure shows them as a sequence of steps for convenience. The report information is gathered by the National Public Safety Commission. If the operator judges that the transaction is not suspicious, it does not go on to the reporting step. The figure does not show, for example, the keeping of verification records, the exceptions to verification at the time of transaction, or the handling of clients who do not respond to verification.

The provisions behind each step in Figure 2 are given in the footnotes, in the order of verification at the time of transaction19, keeping transaction records22, judging suspicious transactions and reporting them2324, and the gathering of information6.

The FSA guidelines

The guidelines call for action in the order of identifying, assessing, and mitigating risks25. The core of mitigation is customer due diligence: at the start, during, and at the end of a relationship, the institution examines what kind of person the client is, who the beneficial owner is if the client is an organization, and what the purpose of the transaction is26. The actions are set out by situation, as in the table below.

Situation Matters requiring action
The client is judged to be high risk Obtain additional information such as assets, income, and source of funds, obtain approval from senior management, and strengthen transaction monitoring and the like (enhanced customer due diligence)27
The client is judged to be low risk Simplified customer due diligence in proportion to the risk, such as raising the thresholds for transaction monitoring, is permitted27
Transaction monitoring Detect transactions that could lead to a suspicious transaction report, using scenarios and thresholds that reflect the risk assessment28
Detecting sanctioned transactions Keep the sanctions lists up to date, and screen without delay when a target is designated by a resolution of the United Nations Security Council or the like28
A transaction is judged to be suspicious Put in place controls to file a report immediately29

For clients and transactions where the necessary information cannot be obtained and appropriate customer due diligence cannot be carried out, institutions are called on to consider cutting off the risk, including declining the transaction. At the same time, an institution must not decline in the name of AML/CFT without a reasonable ground27.

Controls can be organized by the three lines of defense as one method. For some items, controls may be built using a different arrangement30.

The Foreign Exchange and Foreign Trade Act and the Ministry of Finance guidelines

When making a payment or capital transaction for which an obligation to obtain permission has been imposed, residents and non-residents obtain permission1316. When a bank, etc. carries out a funds transfer relating to a client's payment, it confirms before the transaction whether permission is required and, if so, whether it has been obtained17. A person who makes a payment or capital transaction without permission faces imprisonment of up to 3 years or a fine of up to 1 million yen, or both. Where three times the value of the object of the transaction exceeds 1 million yen, the fine can be up to three times the value of that object31.

The Ministry of Finance guidelines call on foreign exchange transaction handlers to do the following. Before carrying out funds transfers and the like, they put in place controls to screen the names of the remitter, the recipient, and others against information on sanctioned parties and so check that the payment is not with a sanctioned party. When a sanctioned party is added, its information is revised, or it is removed, they update the list immediately32. Before starting deposit transactions and the like with a client, they check by screening that the client and its beneficial owner are not sanctioned parties33.

History and points in time

Time Event
July 1989 FATF is established at the Arche Summit4
April 1990 FATF produces the "40 Recommendations"4
October 2001 FATF holds an extraordinary meeting and adds measures against terrorist financing to its mandate4
March 31, 2007 The Act on Prevention of Transfer of Criminal Proceeds (Act No. 22 of 2007) is promulgated34
February 2012 The 40 Recommendations are revised into a new set4
October 2016 The amended Act on Prevention of Transfer of Criminal Proceeds, which introduced risk assessments by the state and by specified business operators, takes effect7
March 31, 2026 The current version of the FSA guidelines is published35
June 2026 The current version of the Ministry of Finance guidelines on compliance with the foreign exchange laws and regulations (the month shown on the cover)8

Differences from other jurisdictions

The AML/CFT law and sanctions mechanism of the US, the AML/CFT law of the EU, and the sanctions mechanism of the UK are compared with Japan.

Jurisdiction Item Content
Japan AML/CFT law Act on Prevention of Transfer of Criminal Proceeds
Japan Sanctions mechanism Permission system under the Foreign Exchange and Foreign Trade Act
Japan Subjects of screening Clients and beneficial owners are screened (Ministry of Finance guidelines)
US AML/CFT law 31 U.S. Code § 5318 requires financial institutions to establish AML/CFT programs. The Secretary of the Treasury may require the reporting of suspicious transactions36
US Sanctions mechanism FAQ 402 addresses the 50 percent rule after blocked persons divest their ownership stakes37
US Treatment of ownership An entity owned 50% or more, directly or indirectly, in the aggregate by one or more blocked persons is deemed to be blocked37
EU AML/CFT law In 2024, a framework of an AML/CFT regulation, a directive, and a regulation establishing the EU's authority (AMLA) was published38
UK Sanctions mechanism Designated persons are placed on the UK sanctions list, and their assets are frozen and similar measures taken39
UK Treatment of ownership and control Asset freezes also reach those owned or controlled, directly or indirectly, by a designated person39

Practical implications

Issue Position in the laws and guidelines
Beneficial owners Sanctions screening is carried out on the beneficial owner as well as on the client33. Confirming the beneficial owner of a corporation falls on the side of verification at the time of transaction19
Dealing with sanctioned parties It is necessary not to make payments or capital transactions with a sanctioned party without permission. When a party is added, screening of clients and beneficial owners is carried out immediately33
Payments to third parties For cross-border funds transfers and the like, even where the remitter and recipient are not direct clients, the FSA guidelines call on institutions to consider enhanced customer due diligence in proportion to risk, in addition to screening against sanctions lists40

This screening is carried out before starting deposit transactions and the like. Consider a hypothetical example in which Bank Y is about to start a deposit relationship with a new corporate client. Bank Y is a foreign exchange transaction handler, and in verification at the time of transaction it confirmed an individual as the corporation's beneficial owner. Under the Ministry of Finance guidelines, before starting the relationship, the bank screens both the client and the beneficial owner to check that neither is a sanctioned party33. When a sanctioned party is added later, it screens both the client and the beneficial owner immediately.

What this page does not cover

EU sanctions, the UK's AML/CFT law, the date the Act on Prevention of Transfer of Criminal Proceeds took effect, and the point in time of the sanctions mechanism under the Foreign Exchange and Foreign Trade Act are not covered on this page.

Notes

  1. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 1 (purpose). The English titles of the guidelines and Ministry of Finance pages in these notes are translations of the meaning, not official names. ↩

  2. "外国為替及び外国貿易法" (Foreign Exchange and Foreign Trade Act, in Japanese), Article 10 (Cabinet decision on countermeasures), Article 16, paragraph 1 (permission for payments, etc.), and Article 21, paragraph 1 (permission for capital transactions). ↩ ↩2 ↩3

  3. Ministry of Finance, "経済制裁措置及び許可手続きの概要" (Outline of economic sanctions measures and permission procedures), the section "タリバーン関係者等・テロリスト等に対する資産凍結等の措置" (Asset freezes and similar measures against Taliban-related persons, terrorists, and others) (in Japanese). ↩

  4. Ministry of Finance, "国際的なマネロン・テロ資金供与・拡散金融対策" (International measures against money laundering, terrorist financing, and proliferation financing) (on FATF's activities), the sections "FATF の沿革" (History of FATF), "40 の勧告" (The 40 Recommendations), and "相互審査の基準とプロセス" (Standards and process of mutual evaluation) (in Japanese). ↩ ↩2 ↩3 ↩4 ↩5

  5. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), II-1 (page 6) and its note (in Japanese). ↩

  6. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 3, paragraphs 2 and 3 (gathering of information by the National Public Safety Commission, and the risk assessment report), and Article 8, paragraphs 5 and 6 (notification of reports). ↩ ↩2

  7. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), I-1 (page 3) and I-4 (page 5) (in Japanese). The reference to the amended Act that took effect in October 2016 is in I-4 (page 5). ↩ ↩2 ↩3

  8. Ministry of Finance, "外国為替取引等取扱業者のための外為法令等の遵守に関するガイドライン" (Guidelines for foreign exchange transaction handlers on compliance with the foreign exchange laws and regulations) (June 2026), the cover (Reiwa 8, June) and Chapter I, 1 (page 1) (in Japanese). ↩ ↩2

  9. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 16, paragraph 1 (on-site inspection) and Article 18 (order for corrective measures). ↩

  10. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 2, paragraph 2, item 21 (financial instruments business operators as defined in Article 2, paragraph 9 of the Financial Instruments and Exchange Act). ↩

  11. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), I-1 (page 1) and I-4 (page 6) (in Japanese). ↩

  12. "犯罪による収益の移転防止に関する法律施行令" (Order for Enforcement of the Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 7, paragraph 1, item 1(ri) and the opening part of the paragraph (exclusion of transactions for which simplified customer due diligence is allowed). The order lists the conclusion of contracts to carry out acts in Article 2, paragraph 8, items 1 to 6 of the "金融商品取引法" (Financial Instruments and Exchange Act, in Japanese; English translation: Japanese Law Translation) and the like; item 4 covers OTC derivative transactions and the like. ↩

  13. "外国為替及び外国貿易法" (Foreign Exchange and Foreign Trade Act, in Japanese), Article 16, paragraph 1. An obligation to obtain permission can be imposed on residents, non-residents, and others who intend to make a payment from Japan to a foreign country. ↩ ↩2

  14. "外国為替及び外国貿易法" (Foreign Exchange and Foreign Trade Act, in Japanese), Article 20, item 8 (between a resident and a non-resident) and item 9 (limitation for transactions between residents). ↩

  15. "外国為替及び外国貿易法" (Foreign Exchange and Foreign Trade Act, in Japanese), Article 6, paragraph 1, item 14 (excluding those specified by Cabinet Order). ↩

  16. "外国為替及び外国貿易法" (Foreign Exchange and Foreign Trade Act, in Japanese), Article 21, paragraph 1. ↩ ↩2

  17. "外国為替及び外国貿易法" (Foreign Exchange and Foreign Trade Act, in Japanese), Article 17 (duty of banks, etc. to confirm). ↩ ↩2 ↩3

  18. "外国為替及び外国貿易法" (Foreign Exchange and Foreign Trade Act, in Japanese), Article 55-9-2, paragraphs 1 to 3. ↩

  19. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 4, paragraph 1. ↩ ↩2 ↩3

  20. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 4, paragraph 2. ↩

  21. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 4, paragraph 3. The exception disapplies the verification in paragraph 1; transactions under paragraph 2 require separate confirmation. ↩

  22. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 7, paragraphs 1 and 3. ↩ ↩2

  23. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 8, paragraph 3 (method of judgment) and Article 3, paragraph 3 (risk assessment report). ↩ ↩2

  24. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), Article 8, paragraphs 1 and 4. ↩ ↩2

  25. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), II-2 (page 7) (in Japanese). ↩

  26. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), II-2 (3)(ii), customer due diligence (page 10) (in Japanese). ↩

  27. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), II-2 (3)(ii), matters requiring action 7, 9, and 11 (pages 11–13) (in Japanese). ↩ ↩2 ↩3

  28. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), II-2 (3)(iii), transaction monitoring and screening, matters requiring action 1 and 2 (page 13) (in Japanese). ↩ ↩2

  29. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), II-2 (3)(v), reporting of suspicious transactions, matters requiring action 5 (pages 14–15) (in Japanese). ↩

  30. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), III-3 (pages 22–23) (in Japanese). ↩

  31. "外国為替及び外国貿易法" (Foreign Exchange and Foreign Trade Act, in Japanese), Article 70, paragraph 1, item 3 (permission under Article 16) and item 7 (permission under Article 21). ↩

  32. Ministry of Finance, "外国為替取引等取扱業者のための外為法令等の遵守に関するガイドライン" (Guidelines for foreign exchange transaction handlers on compliance with the foreign exchange laws and regulations) (June 2026), II-4-(1)-1 and 2 (page 11) (in Japanese). ↩

  33. Ministry of Finance, "外国為替取引等取扱業者のための外為法令等の遵守に関するガイドライン" (Guidelines for foreign exchange transaction handlers on compliance with the foreign exchange laws and regulations) (June 2026), II-4-(3)-1 (page 13) (in Japanese). ↩ ↩2 ↩3 ↩4 ↩5

  34. "犯罪による収益の移転防止に関する法律" (Act on Prevention of Transfer of Criminal Proceeds, in Japanese), the title section of the e-Gov text (Act No. 22 of 2007, promulgated on March 31). ↩

  35. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism), the cover (Reiwa 8, March 31) (in Japanese). ↩

  36. 31 U.S.C. § 5318(h)(1) and (g)(1) (Cornell LII). ↩

  37. U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), FAQ 402 (the 50 percent rule). ↩ ↩2

  38. European Commission, "Anti-money laundering and countering the financing of terrorism at EU level", the policy timeline (published in the Official Journal on June 19, 2024) and the "Relevant legislation" section. The AML/CFT regulation is Regulation (EU) 2024/1624, which the same page presents as applying "from 2027". ↩

  39. HM Treasury, Office of Financial Sanctions Implementation (OFSI), "UK financial sanctions general guidance" (updated May 12, 2026), 1.3 and 3.1. ↩ ↩2

  40. Financial Services Agency, "マネー・ローンダリング及びテロ資金供与対策に関するガイドライン" (Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism) (March 31, 2026), II-2 (4)(i), cross-border funds transfers and the like, matters requiring action 8 (page 18) (in Japanese). ↩

  41. Ministry of Finance, "外国為替取引等取扱業者のための外為法令等の遵守に関するガイドライン" (Guidelines for foreign exchange transaction handlers on compliance with the foreign exchange laws and regulations) (June 2026), II-4-(1)-4 (page 11) (in Japanese). ↩