Recent Trends in Japan’s Sanctions Against Russia on the Prevention of Evasion and Circumvention

Since Russia began its invasion of Ukraine, Japan has imposed various sanctions against Russia （“Russia Sanctions”） under the Foreign Exchange and Foreign Trade Act of Japan （"Act"）, in cooperation with other major countries, including the United States and the European Union. Recently, it has been pointed out that there have been cases involving evasion or circumvention of the sanctions against Russia introduced by major countries; in response, major countries have agreed to strengthen measures aimed at preventing these evasive actions. In this context, while maintaining the existing framework of the Russia Sanctions, Japan recently announced that certain circumventive or evasive acts are subject to the Russia Sanctions, and detailed specific items to which companies should...To read the full article, please see the PDF file

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Authors

Kazuho NAKAJIMA

Partner
Tokyo

He has extensive experience handling cases involving complex legal issues, such as mergers and acquisitions by a public-private investment fund in the context of a business turnaround, a high-value dispute between a securities company and a stock exchange, adoption of anti-takeover defense measures for the first time in Japan, expansion of foreign businesses into the Middle East involving geopolitical risks, and commercial arbitration involving sizable claims regarding M&A price adjustment clauses. Recently, he been advising on risk assessments for transactions, contract drafting, voluntary self-disclosure to government authorities, responses to enforcement actions by the authorities, and establishment of internal control systems with respect to economic security regulations. In particular, he engages in numerous transactions involving economic sanctions, export controls and other economic security regulations regarding conflicts between the US and China over technology competition and human rights issues in Myanmar, Iran and Russia.

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