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Sanctions Tracker Japan

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    Tracker of Sanctions in response to Ukraine Crisis

    这种跟踪是一个高级的措施的总结es 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 2 June 2023.

    Date of imposition Sanction imposed Summary
    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
    1)资产冻结(payme (a)限制nts 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 viewedhere(starting from p. 3).

    ii) Ban on any export tothe designated 80 Russian entities.

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

    (四)禁止提供建筑和女士eering 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
    1)资产冻结(payme (a)限制nts 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 viewedhere(starting from p. 3).
    ii) Ban on any export tothe 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 2023 Asset freeze i) 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 accessedhere(starting from p. 3).
    Ban on export to Russian designated entities Ban 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 2022 Ban on the import of crude oil originating from Russia traded above the designated price cap i) 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 of5 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 2022 Designation 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 from7 October 2022.

    This measure was approved following a decision by G7 foreign ministers late September.
    26 September 2022 Ban on export to designated entities in Russia Ban on export to21 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 Russia Ban on export of the goods related to chemical weapon to the Russian Federation.
    5 July 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 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 Belarus Ban on export to65 entities of the Russian Federation and 25 entities of the Republic of Belarus that have been designated as specified entitiesin 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 Russia Pursuant 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 commencingon or after 5 September 2022.
    Ban on precious metals (gold) import from Russia Measures 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 from7 July 2022).
    10 May 2022 Asset freeze 我)限制支付,2)限制on capital transactions (bank deposit contracts, trust agreements, money loan contracts) with,the designated 8 individuals associated with the Russian Federationand133 individuals associated with the self-proclaimed Donetsk People's Republic and Luhansk People's Republic.
    Ban on the export to certain entities in Russia Exportsto 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 ofhigh-tech goodsto 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 ofRussian oilto be less dependent on Russia in the energy sector.
    12 April 2022 Asset freeze 我)限制支付,2)限制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 thetwo banks(Sberbank and Alfa Bank) will take effect on12 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 after12 May 2022.
    Ban on the import of certain types of goods from Russia Approvals 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 2022 Ban 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 theexport of luxury goods from Japan to Russiafrom5 April 2022. The luxury goods subject to this ban are as follows:

    • Liquor;
    • Tobacco products;
    • perfume, cosmetics;
    • leather goods;
    • fur;
    • clothing, shoes;
    • hats;
    • 地毯;
    • 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 2022 Asset freeze 我)限制支付,2)限制on capital transactions (bank deposit contracts, trust agreements, money loan contracts) withthe designated 25 individuals associated with the Russian Federation.
    Ban on export to designated Russian entities Ban on the export tothe designated 81 entities in the Russian Federation(please see the list starting from p. 7 of the PDF file; in Japanese).
    18 March 2022 Asset freeze 我)限制支付,2)限制on capital transactions (bank deposit contracts, trust agreements, money loan contracts) withthe designated 15 individuals and 9 entities associated with the Russian Federation
    16 March 2022 Revoking of "Most-favoured nation" trade status for Russia On 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 2022 Announcement 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 postedslides 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 freeze 我)限制支付,2)限制on capital transactions (bank deposit contracts, trust agreements, money loan contracts) with thedesignated 17 individuals associated with the Russian Federation
    11 March 2022 Belarus:Asset freeze/ financial restrictions

    From10 April2022, 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 thelist(in English/Japanese)

    8 March 2022 Asset 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 thelist(in English/Japanese)

    Trade restrictions– petroleum refinery equipment Prohibition of export ofpetroleum refinery equipmentto 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 2022 Asset 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 (from2 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 thelist(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 2022 Asset 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 from8 March 2022.

    28 February 2022

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

    Financial restrictions – Russian Central Bank Restrictions on transactions with the Russian Central Bank.
    Sanctions against Belarus Sanctions 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 access Removal 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 freeze66in 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. 权限必须获得进入资本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


    Footnotes


    67. Measures such as asset freeze against one entity that has been designated as an entity in the Russian Federation (i.e., Bank Rossiya) will be implemented from 28 March 2022.

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