In the area of Anti-Money Laundering (AML), the Japanese authorities are preparing for the next round of FATF mutual evaluation scheduled for as early as in 2025. The authorities’ expectation level is quite high, particularly in terms of the customer refresh cycle and timeline for screening sanctioned people. Their approach, however, is rather inflexible and not truly consistent with a risk-based approach recommended by the FATF or practiced by global banks for many years. Recently, there are signs of showing some flexibility but still not enough. In April 2024, a new regime of additional requirements of screening sanctioned people will be introduced.


  • The EBC hopes the regime will be implemented in a flexible and practical manner so that it would not constrain cross-border banking.