AML

In the area of Anti-Money Laundering (AML), Japanese authorities are preparing for the next round of FATF mutual evaluation, after shifting gears from a rules-based to a principles-based approach. In April 2024, the FSA revised its guidance, no longer requiring a strict time limit of 24 hours on the screening of persons under sanctions, and allowing customer “refresh cycles” other than the previously-prescribed “1-2-3 years cycles”, except in situations where additional, higher risks may be considered. Nevertheless, the establishment of a central repository of information on the Ultimate Beneficial Owners (UBOs) of companies, an area for improvement announced by the Government in August 2021 in response to the FATF’s evaluation report of Japan, appears to have encountered some delays. As of April 2025, there is no clear sign of progress on this issue.