Authored by our Global Sanctions Team

On March 1, 2022 and March 3, 2022, Japan's Ministry of Foreign Affairs ("MOFA"), Ministry of Finance ("MOF") and Ministry of Economy, Trade and Industry ("METI") jointly announced "Measures Related to the Situation in Ukraine under the Foreign Exchange and Foreign Trade Act" (the "Statements").¹

Measures

On March 1, 2022, Japan implemented additional sanctions against Russia, following those of February 25, 2022, which are summarized here:

• Assets Freeze:²

  • Restrictions on payments: Japan restricted payments to six Russian individuals (including Vladimir Putin) and three designated banks (collectively the "Additional Designated Russian Persons (March1 )"³).
  • Restrictions on capital transactions: Permission is required for capital transactions (i.e., contracts of deposit, trusts and money loans) with the Additional Designated Russian Persons (March 1).
• Restrictions on exports, etc. and related payments:
  • Japan will restrict exports and payments to 49 designated Russian entities.⁴ As of March 7, 2022, the details of such export restrictions have not been announced but the restrictions on payments have taken effect.⁵
• Further Export Controls Against the Russian Federation:
  • According to the Statements, Japan will impose restrictions on exports of general goods that could strengthen the military capacity of the Russian Federation. As of March 7, 2022, the details of the scope of the additional export controls have not been announced.

On March 3, 2022, Japan implemented the following additional measures related to Russia, Belarus, the Donetsk Republic and the Luhansk Republic:

• Asset Freeze:⁶
  • Restrictions on payments: Japan restricted payments to 18 Russian individuals, four Russian banks,⁷ seven Belarussian individuals, two Belarussian entities⁸ and 30 individuals related to the Donetsk Republic and the Luhansk Republic (collectively, "Additional Designated Persons (March 3)"⁹).
  • Restrictions on capital transactions: Permission is required for the Additional Designated Persons (March 3) for capital transactions.

• Tightening of export controls of items and relevant services subject to Multilateral Export Control Regimes to Belarus:
  • Examination procedures for exports of items and relevant services subject to Multilateral Export Control Regimes to Belarus have been tightened by removing bulk license exemptions for Belarus.

1 The full Statements in Japanese are available here (March 1 Statement and March 3 Statement).
2 The measures against the listed designated Russian banks (other than the Central Bank of the Russian Federation) will be effective from March 31, 2022.
3 The list of Additional Designated Russian Persons as of March 1, 2022, are available here.
4 The list of the additional designated 49 entities as of March 1, 2022 are available here.
5 Effective from March 8, 2022.
6 The measures against the listed additional designated Russian banks will be effective from 2 April 2022, while the measures against the other designated individuals/entities here are effective from 3 March 2022.
7 The list additional designated Russian individuals and banks as of 3 March 2022 are available here.
8 The list designated Belarussian individuals and entities as of 3 March 2022 are available here.
9 The list additional designated individuals related to Donetsk Republic and Luhansk Republic as of 3 March 2022 are available here.

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