Preliminary applications for over 2,000,000yen

Our response to Foreign Currency Exchange Transactions in light of the economic sanctions against Russia.

However, due to Russia's recent invasion of Ukraine, the United States and Europe have imposed a series of strong economic sanctions against Russia and Belarus, and Japan has also been imposing and strengthening economic sanctions against Russia and Belarus since February 26, 2022.

In light of this situation, we are unable to handle transactions that fall under the following "Transactions we are unable to handle".

Customers conducting foreign currency exchange transactions (including the purchase of traveler's checks) are requested to make sure that the transaction does not fall under any of these categories before making a request.

Our Policy on Foreign Currency Exchange Transactions in Light of U.S. OFAC Regulations, etc.

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury imposes measures such as trade bans and asset freezes on countries and regions designated by the United States and certain individuals and organizations for foreign policy and national security purposes, and such regulations are called OFAC regulations.

 

OFAC regulations apply to U.S. persons and U.S. corporations, including U.S. financial institutions, as well as foreign persons and foreign corporations located in the U.S. Mainly, transactions with a U.S. contact point, such as those denominated in U.S. dollars that are settled in the U.S., are subject to OFAC regulations. Even for foreign currency exchange transactions accepted in Japan, transactions in U.S. dollars involving "sanctioned persons" are subject to OFAC regulations, and in such cases, not only the transaction in question but also subsequent transactions may be hindered, such as being restricted by foreign banks.

 

Under some sanctions programs, such as Iran sanctions, Foreign Financial Institutions (including banks located in Japan), non-U.S. companies (Japanese companies, etc.), and individuals who have no contact with the U.S. may be prohibited from accessing the U.S. foreign currency exchange market, importing goods (into the U.S.), and trading property in the U.S. as part of secondary sanctions. As part of secondary sanctions, you may be prohibited from accessing the U.S. foreign exchange market, restricted from importing goods (into the U.S.), or prohibited from trading in goods (property) in the U.S., and may be designated as a "sanctioned person". In order to protect not only our company but also our customers from the risk of such sanctions, we may conduct a thorough investigation not only at the time the transaction is handled, but also after the fact, and investigate related parties (subsidiaries, affiliates, etc.) over which our customers have capital or control.

 

It is our policy not to handle transactions, in principle or in any currency, involving or related to countries subject to comprehensive sanctions (Iran, North Korea, Cuba, Syria, Crimea, Donetsk People's Republic (self-proclaimed), Luhansk People's Republic (self-proclaimed)), whether directly or indirectly.
We will comply with the laws and spirit of the applicable local economic sanctions laws in all regions in which we operate. We prohibit any attempt to circumvent or evade sanctions. Customers conducting foreign currency exchange transactions (including the purchase of traveler's checks) are requested to make sure that their transactions do not fall under any of these categories before making a request.

 

If, after receiving the transaction, there is a possibility that the transaction may fall under economic sanctions regulations (including OFAC), we will confirm the details of the transaction and, depending on the results, we may request that the transaction be cancelled or that further transactions be rejected, depending on the results of the review.

 

In the event of assets freeze due to OFAC regulations, we will not be able to return funds deposited as payment in lieu of a transaction. In such cases, please be advised that you will be required to take appropriate action, such as applying to OFAC for the unfreezing of your funds. The above is only an example. Please refer to the OFAC website for details on OFAC regulations.

http://www.treasury.gov/resource-center/sanctions/Pages/default.aspx

Regulations on Payment, etc. under the Foreign Exchange and Foreign Trade Law.

In order to ensure the implementation of economic sanctions under the "Foreign Exchange and Foreign Trade Law" (hereinafter referred to as the "Foreign Exchange Law"), we have confirmed that your currency exchange transactions do not fall under or relate to "restrictions on trade-related payments," "restrictions on the use of funds," "restrictions on outward direct investment," or "restrictions on service transactions," etc., in light of the intent of Article 17 of the Foreign Exchange Law. We have confirmed that the customer's exchange transactions do not fall under or are not related to "restrictions on trade-related payments," "restrictions on the use of funds," "restrictions on foreign direct investment," or "restrictions on service transactions. We appreciate your understanding and cooperation.

 

　

Please declare the purpose of exchange.
1. Please declare the purpose of exchange, and if the purpose is for imports or intermediary trade, please also declare the commodity item, place of origin (name of country), shipping area (name of city), and destination (name of country) (in the case of intermediary trade).
2. Please confirm that the transaction does not fall under the category of "transactions regulated by North Korea or Iran" under the Foreign Exchange and Foreign Trade Control Law, nor does it fall under the category of the latest Russia-related regulated transactions, and please declare such to that effect.

 

Please confirm the counterparty to the transaction.
To the best of your knowledge, please confirm that the ultimate recipient of the exchanged funds is not a North Korean resident, and that none of the main shareholders or directors of the counterparty to the transaction is a North Korean resident (corporate or individual), and declare that the transaction is not a "North Korea/Iran Regulation-related transaction.

 

We may ask you to present documents that can confirm the details of your transaction.
When accepting a transaction at the counter, you may be asked to present materials related to the transaction to confirm the details of the transaction by documents. Please note that we may have to decline your transaction if we cannot confirm that the transaction does not fall under the "Restrictions on Trade-related Payments," "Restrictions on Use of Funds," "Prohibition of Payments to Residents of North Korea," "Restrictions on Foreign Direct Investment," or "Restrictions on Service Transactions”.
We ask for your understanding in advance.

 

Please confirm the latest regulations regarding Russia-related regulations in the Ministry of Finance Notification or on the Ministry of Finance website.
Following Russia's invasion of Ukraine in February 2022, various regulations based on the Foreign Exchange and Foreign Trade Law are in effect from time to time.

Ministry of Finance | Economic Sanctions and Permit Procedures (Japanese only)