Trending topics

Russia Sanctions Tracker - Japan

Insight Hero Image

    << Russia Sanctions Tracker

    This tracker is a high-level summary of the measures imposed by Japan following Russia's invasion of Ukraine in February 2022.

    In the current circumstances, the status of these measures are subject to change on a daily basis. Certain measures were in place prior to February 2022 and these are not included in this tracker. Whilst every effort has been made to ensure the accuracy and completeness of this summary at the date of publication, no reliance should be placed on its content and it does not constitute legal advice. Please refer to the primary sources of the restrictions for their full content.

    This tracker was last updated on 13 February 2024.

    Date of impositionSanction imposed Summary 
     27 December 2023Asset freeze, ban on export to designated entities in Russia and the countries other than Russia and Belarus, ban on import of non-industrial diamond from Russia
    (i) Asset freeze: ((a) Restriction on payments and (b) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts)) targeting 19 Russian individuals and 43 Russian entities as well as 16 individuals of the eastern/southern Ukraine and 1 entity from a country other than the Russian Federation and the Republic of Belarus, who are determined as directly causing the annexation of Crimea and Sevastopol to the Russian Federation/the unrest in the eastern Ukraine. A full list of the individuals and entities subject to the asset freeze can be viewed here (starting from p. 3).

    (ii) Ban on any export to 57 Russian entities and 6 non-Russian/non-Belarusian entities designated by the Ministry of Foreign Affairs notice published on 15 December 2023.

    (iii) Ban on the import of non-industrial diamonds from the Russian Federation.
     9 August 2023Ban on export of goods that facilitate strengthening Russian industrial baseThe Export Trade Control Order of Japan was partially revised to ban any export of goods that facilitate strengthening the Russian industrial base. Some examples of the goods subject to the ban this time are as follows: luxury cars (new and used vehicles over 1900 cc), hybrid engine passenger cars, large vehicle tyres.
    26 May 2023
    Asset freeze, ban on export to Russian designated entities, ban on export of goods that facilitate strengthening Russian industry, ban on the provision of construction and engineering services for Russia
    i) Asset freeze ((a) Restriction on payments and (b) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts)) targeting 17 Russian individuals and 78 Russian entities as well as 7 individuals, who are determined as being the persons directly involved in causing the unrest in the eastern and southern Ukraine. A full list of the individuals and entities subject to the asset freeze can be viewed here (starting from p. 3).

    ii) Ban on any export to the designated 80 Russian entities.

    iii) Ban on the export of goods that facilitate strengthening the industry of the Russian Federation.

    iv) Ban on the provision of construction and engineering services for the Russian Federation.
    7 April 2023
    Addition to the embargoed goods
    More goods were added to the list of the goods subject to the export ban concerning Russia. Some examples of the newly banned goods are steel, aluminium, construction machines (hydraulic shovels, bulldozers, etc.) and electronic devices.
    30 March 2023
    Asset freeze, ban on export to Russian designated entities, ban on export of goods that facilitate strengthening Russian industry
    i) Asset freeze ((a) Restriction on payments and (b) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts)) targeting 39 Russian individuals, 73 Russian entities, 1 designated bank in the Russian Federation (Rosbank) and 9 individuals, who are determined as being the persons directly involved in the "annexation" conduct by the Russian Federation. A full list of the individuals and entities subject to the asset freeze can be viewed here (starting from p. 3).
    ii) Ban on any export to the designated 21 Russian entities.
    iii) Ban on the export of goods that facilitate strengthening the industry of the Russian Federation.
    6 February 2023
    Ban on the import of Russian-origin petroleum products traded above the designated price cap and the provision of services that are related to such products
    i) Embargo on any Russian-origin petroleum products traded above the price cap designated by the Ministry of Foreign Affairs on 6 February 2023: government approvals must be obtained prior to the import of such products; not applicable to any imports based on any contracts signed prior to 6 February 2023 of the goods that will be unloaded from ships in Japan before 1 April 2023;

    ii) Permissions must be obtained for any loan agreement, debt guarantee and setoff and provision of the services specified by the Ministry of Finance and Ministry of Economy, Trade and Industry (including trade intermediary services) relating to the purchase of the Russian-origin petroleum products that are transported by sea.
    27 January 2023Asset freezei) Restriction on payments and ii) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts)) targeting 3 Russian entities and 22 Russian individuals, including aircraft company JSC Irkut Corp and deputy defence minister Mikhail Mizintsev.

    14 individuals assumed to be contributing to the instability in eastern Ukraine are also subject to the asset freeze.

    The full list of the individuals and entities subject to the asset freeze can be accessed here (starting from p. 3).
    Ban on export to Russian designated entitiesBan on any export to 49 designated Russian entities.
    Ban on export of dual-use goods Ban on the export of dual-use goods that can be potentially used to enhance the military capability of Russia. The banned items include water cannons, gas exploration equipment and semiconductor equipment.
    5 December 2022Ban on the import of crude oil originating from Russia traded above the designated price capi) Ban on the import of crude oil originating from the Russian Federation traded above the cap price designated by the Ministry of Foreign Affairs public notice as of 5 December, 2022.

    ii) Ban on the provision of the services related to the purchase of the crude oil traded above the price cap and transported by sea (such as brokering services, financing and financial assistance).

    The crude oil produced in the Sakhalin 2 project is excluded from the scope of this measure.
    30 September 2022Designation of the specific goods subject to the export control Partial revision of the Cabinet Order on Export Trade Control was announced to introduce the measure to ban any export of the goods related to chemical weapons to the Russian Federation. This ban will be effective from 7 October 2022.

    This measure was approved following a decision by G7 foreign ministers late September.
    26 September 2022Ban on export to designated entities in RussiaBan on export to 21 entities in the Russian Federation subject to the designation announced by the Ministry of Foreign Affairs public notice dated 26 September.
    Ban on export of chemical weapons goods to RussiaBan on export of the goods related to chemical weapon to the Russian Federation.
    5 July 2022Asset freezei) Restriction on payments to and ii) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts) with, the designated 57 individuals and 6 entities related to the Russian Federation and 5 individuals determined to be directly involved in the unrest in eastern Ukraine. Dmitry Grigorenko, Deputy Prime Minister of the Russian Federation, is among the sanctioned individuals.
    Ban on export to specific entities in Russia and BelarusBan on export to 65 entities of the Russian Federation and 25 entities of the Republic of Belarus that have been designated as specified entities in the Ministry of Foreign Affairs Public Notice released on 5 July. AO Rubin is among the sanctioned entities.
    Ban on the provision of services for RussiaPursuant to the Ministry of Foreign Affairs Public Notice released on 5 July, permissions must be obtained to provide trust services, accounting & auditing services and/or business management consulting services for the Russian Federation. This sanction will be applied to the service transactions commencing on or after 5 September 2022.
    Ban on precious metals (gold) import from RussiaMeasures to ban import of precious metals (gold) from the Russian Federation will be introduced. Further notice will be released from the Ministry of Finance later.

     10 June 2022

     Ban on the export of the goods that have potentials to strengthen the industrial base in Russia
     Introduction of the measures to ban exports of the goods that have potentials to strengthen the industrial base in Russia.  The regulated goods include plywood, steel storage tanks, freight vehicles, bulldozers and transformers).  This ban will become effective on 17 June 2022.
     7 June 2022 Asset freeze i) Restriction on payments to and ii) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts) with, the designated 2 banks in the Russian Federation (Credit Bank of Moscow; Russian Agricultural Bank/Rosselkhozbank) and 1 bank in the Republic of Belarus (Belinvestbank/Belarusian Bank for Development and Reconstruction) (the asset freeze of these banks will be enforced on and from 7 July 2022).
     10 May 2022 Asset freeze i) Restriction on payments to, and ii) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts) with, the designated 8 individuals associated with the Russian Federation and 133 individuals associated with the self-proclaimed Donetsk People's Republic and Luhansk People's Republic.
    Ban on the export to certain entities in RussiaExports to 71 entities designated as the specified entities of the Russian Federation will be banned.

    Ban on the export of high tech goods to Russia

    (announced but not yet implemented)

    Measures for prohibiting the export of high-tech goods to the Russian Federation will be introduced.
    Energy policy to phase out imports of Russian oil Prime Minister Fumio Kishida announced a policy to phase out imports of Russian oil to be less dependent on Russia in the energy sector.
    12 April 2022Asset freezei) Restriction on payments to, and ii) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts) with, the designated individuals/entities (398 individuals including President Putin's 2 daughters; 28 entities including Sberbank) associated with the Russian Federation (the list of the sanctioned individuals and entities start from page 2).

    The asset freeze of the two banks (Sberbank and Alfa Bank) will take effect on 12 May 2022.
    Ban on new foreign direct investment to Russia Approvals must be obtained for any new foreign direct investment to Russia that will commence on and after 12 May 2022.
    Ban on the import of certain types of goods from RussiaApprovals must be obtained for any import of certain types of goods, such as alcoholic beverages, from Russia. Any import under contracts that were already effective prior to the sanction are subject to a grace period of 3 months.
    29 March 2022Ban on export of luxury goods from Japan to Russia

    An announcement was made on 29 March 2022 to partially amend the Cabinet Order on Export Trade Control of Japan to prohibit the export of luxury goods from Japan to Russia from 5 April 2022. The luxury goods subject to this ban are as follows:

    • Liquor;
    • Tobacco products;
    • perfume, cosmetics;
    • leather goods;
    • fur;
    • clothing, shoes;
    • hats;
    • carpets;
    • jewellery;
    • porcelains;
    • glass products;
    • diving equipment;
    • passenger vehicles, motorbikes;
    • laptop PCs;
    • watches with precious metals;
    • grand pianos; and
    • work of art and antiques.
    25 March 2022Asset freezei) Restriction on payments to, and ii) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts) with the designated 25 individuals associated with the Russian Federation.
    Ban on export to designated Russian entitiesBan on the export to the designated 81 entities in the Russian Federation (please see the list starting from p. 7 of the PDF file; in Japanese).
    18 March 2022Asset freezei) Restriction on payments to, and ii) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts) with the designated 15 individuals and 9 entities associated with the Russian Federation
    16 March 2022Revoking of "Most-favoured nation" trade status for RussiaOn 16 March 2022, the Prime Minister's Office of Japan announced its plan to strip Russia of its "most-favoured nation" status to punish Moscow for its aggression in Ukraine.
    15 March 2022Announcement of the revisions of the Cabinet Order on Export Trade Control related to the prohibition of exports to Russia and Belarus

    These revisions of the Cabinet Order on Export Trade Control are related to the series of the ban on the exports to Russia and Belarus announced by Japan up to 8 March 2022. The revisions will take effect on 18 March 2022. As a general rule, export of certain goods to certain destinations are subject to government approvals. The Ministry of Economy, Trade and Industry has posted slides on the METI website that provides clarifications on the revisions, including a flowchart concerning the procedures to obtain approvals for export to Russia and other countries/regions subject to the sanctions (in Japanese).
    Asset freezei) Restriction on payments to, and ii) restriction on capital transactions (bank deposit contracts, trust agreements, money loan contracts) with the designated 17 individuals associated with the Russian Federation
    11 March 2022Belarus: Asset freeze / financial restrictions

    From 10 April 2022, a restriction on i) payments to, and ii) capital transactions (bank deposit contracts, trust agreements, money loan contracts) with, three banks of the Republic of Belarus:

    • Belagroprombank
    • Bank Dabrabyt
    • Development Bank of the Republic of Belarus

    Access the list (in English/Japanese)

    8 March 2022Asset freeze

    A restriction on i) payments to, and ii) capital transactions (bank deposit contracts, trust agreements, money loan contracts) with:

    • Russia – 20 individuals / 2 entities
    • Belarus – 12 individuals / 10 entities

    Access the list (in English/Japanese)

    Trade restrictions – petroleum refinery equipment Prohibition of export of petroleum refinery equipment to the Russian Federation
    Belarus: trade restrictions

    From 15 March 2022, a ban on:

    • exports to two newly designated entities; and
    • the receipt of any payment related to the export to such designated entities
    Belarus: trade restrictions - dual use goods Ban on the dual-use goods which are believed to help strengthen the military capabilities of the Republic of Belarus
     3 March 2022Asset freeze

     A restriction on i) payments to, and ii) capital transactions (bank deposit contracts, trust agreements, money loan contracts) with:

    • 18 Russian Federation officials
    • 4 Russian Banks (from 2 April 2022) - VTB Bank, Sovcombank, Novikombank, Bank Otkritie
    • Belarusian Republic officials - 7 individuals and 2 groups
    • 30 individuals in connection with the self-proclaimed Donetsk People's Republic and the self-proclaimed Luhansk People's Republic

    Access the list (in English/Japanese)

    Belarus: trade restrictions
    Ban on the export of the controlled items on the list managed by the multilateral export control regime (NSG, AG, MTCR and WA) to the Republic of Belarus.
    1 March 2022Asset freeze

    Four entities: Bank Rossiya; Promsvyazbank; VEB RF (Vnesheconombank), Central Bank of Russian Federation.

    Six individuals: Vladimir Putin, Sergey Lavrov, Sergey Shoygu, Valery Gerasimov, Nikolai Patrushev, Dmitry Medvedev. 

    Financial / export restrictions

    (The Public Notice of 1 March 2022 by the Ministry of Foreign Affairs)

    Ban on the receipt of payments pertaining to any export to 49 specified military-related entities from 8 March 2022.

    28 February 2022

    (Announced by Prime Minister Kishida at the press conference on 28 February 2022

    Financial restrictions – Russian Central BankRestrictions on transactions with the Russian Central Bank.
    Sanctions against BelarusSanctions against specific individuals and entities including President Lukashenko; export control measures
    27 February 2022
    (Announced by Prime Minister Kishida at the press conference on 27 February 2022)

    Asset freeze Asset freeze against President Putin and other individuals related to the Russian government but not yet implemented. The individuals related to the Russian government and the Russia-related entities subject to the asset freeze have not been specified yet
    Restrictions on SWIFT accessRemoval of selected Russian banks from the SWIFT messaging system – announced in the joint statement from the EC, France, Germany, Italy, the UK, Canada, the US and Japan (the "Joint Statement") but not yet implemented.
    26 February 2022

    Asset freeze

    Regarding the Measures based on the Foreign Exchange and Foreign Trade Act concerning the Situation in Ukraine (Japanese)

    The following measures (i) and (ii) will be implemented in respect of 24 individuals who have been designated as the individuals associated with Donetsk People's Republic ("Donetsk") and Luhansk People's Republic ("Luhansk") and 1 entity that has been designated as an entity in the Russian Federation subject to the measures such as asset freeze 66 in the Public Notice of 26 February by the Ministry of Foreign Affairs:

    1. Permissions must be obtained to make payments to the designated individuals and/or entity notified in the Public Notice of 26 February by the Ministry of Foreign Affairs;
    2. Permissions must be obtained to enter into capital transactions (bank deposit contracts, trust agreements, money loan agreements) with the designated individuals and/or entity notified in the Public Notice of 26 February by the Ministry of Foreign Affairs.

    24 individuals:

    Vladimir BIDYOVKA, Olga (Ol'ga) MAKEEVA, Alexandr ANANCHENKO, Vladimir ANTONOV, Tatiana (Tatyana) PEREVERZEVA, Aleksei (Alexey) DIKIY, Vladimir PAVLENKO, Nataliya NIKONOROVA, Igor ANTIPOV, Aleksei (Alexey) KOSTRUBITSKY, Yuriy (Yurii) SIROVATKO, Leonid PASECHNIK, Denis (Denys) MIROSHNICHENKO, Dmitrii (Dmitry) KHOROSHILOV, Andrei (Andrey) SOPELNIK, Oleg KOVAL, Sergei (Sergey) KOZLOV, Yurii (Yuriy) GOVTVIN, Elena KOSTENKO, Anna TODOROVA, Igor KORNET, Evgenii KATCAVALOV, Zaur

    One Russian bank: Bank Rossiya

    Ban on export to Donetsk or Luhansk

    Regarding the Measures based on the Foreign Exchange and Foreign Trade Act concerning the Situation in Ukraine (Japanese)

    Limited to cases where Donetsk or Luhansk is the destination.

    Ban on import from Donetsk or Luhansk

    Regarding the Measures based on the Foreign Exchange and Foreign Trade Act concerning the Situation in Ukraine (Japanese)

    Limited to cases where Donetsk or Luhansk is the country of origin.

    Prohibition of the issuances and transactions of new Russian sovereign debt in the primary and secondary market in Japan

    Regarding the Measures based on the Foreign Exchange and Foreign Trade Act concerning the Situation in Ukraine (Japanese)

    • Regulation on the issuance or offering of sovereign debt in Japan by the Government of the Russian Federation and the Government Agencies of the Russian Federation and the Central Bank of the Russian Federation designated by the Public Notice of 26 February by the Ministry of Foreign Affairs (the "Russian Government"): Permission must be obtained for making such issuance or offering;
    • Regulation on the acquisition or transfer of sovereign debt newly issued by the Russian Government: Permission must be obtained for the acquisition of newly issued sovereign debt by a resident in Japan from a non-resident or the transfer by a resident in Japan to a non-resident;
    • Permission must be obtained for the provision of service or benefits by a resident in Japan for the purpose of new issuance or offering of sovereign debt in Japan by the Russian Government

    Prohibition of bond issuances by designated Russian banks

    Regarding the Measures based on the Foreign Exchange and Foreign Trade Act concerning the Situation in Ukraine (Japanese)

    Security bonds having 30 days or more until the redemption date issued by the specific banks of the Russian Federation, by which issuance of bonds in Japan is banned, will be subject to the prohibition.

    Sanctions on the exports of controlled items listed on the internationally agreed list to the Russian Federation

    Regarding the Measures based on the Foreign Exchange and Foreign Trade Act concerning the Situation in Ukraine (Japanese)

    Sanctions on the exports to the Russian Federation and Russian military-related entities: Screening processes will be further tightened with regards to the export of controlled items listed on the internationally agreed list to the Russian Federation and Russian military-related entities and of other dual-use goods such as semiconductors.

    Additional contributors: Motoko Kawakami

    The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
    Readers should take legal advice before applying it to specific issues or transactions.

    image

    Stay ahead with our business insights, updates and podcasts

    Sign-up to select your areas of interest

    Sign-up