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Our Corporate Position on Economic Sanctions

Japan Remit Finance Co., Ltd. (October 2023)

 

In order to appropriately respond to the economic sanctions imposed on relevant countries and international organizations, Japan Remit Finance Co., Ltd. (“JRF” or “We”) hereby confirms that we do not fall under any of the transactions subject to Japanese regulations, such as the Foreign Exchange and Foreign Trade Law (hereinafter referred to as the Foreign Exchange and Foreign Trade Law), when we accept foreign exchange transactions, etc. requested by the customers

 

When requesting foreign exchange transactions, etc., please make sure at first that they do not fall within the scope of the Foreign Exchange and Foreign Trade Control Law or OFAC regulations in the United States, and then proceed with the procedures.

We may ask you to confirm the details of the transaction, such as background and purpose, or request you to submit a document that explains the details of the transaction. After that, we might decline the requested transaction.

 

Countries with restrictions

We designate non-remittance recipient countries. and cannot respond to customer requests if the transaction involves direct or indirect elements with those countries, etc.

The list of non-remittance recipient countries as of October 2023 are as follows.

North Korea, Iran, Albania, Croatia, Kosovo, Serbia, Bulgaria, Bosnia and Herzegovina, Belarus, Macedonia, Moldova, Lithuania, Romania, Russia, Kazakhstan, Tajikistan, Uzbekistan, Kyrgyz Republic, Armenia, Azerbaijan, Crimea, Ukraine, Turkmenistan, Burundi, Central African Republic, Democratic Republic of Congo, Ethiopia, Iraq, Lebanon, Libya, Mali, Nicaragua, Venezuela, Yemen, Zimbabwe, Guinea-Bissau, Jamaica, Haiti, Syria, Cuba, and Myanmar

 

Foreign Exchange Law regulations

We have confirmed that the customer’s foreign exchange transactions do not fall under the subject of regulations under the Foreign Exchange and Foreign Trade Control Law (hereinafter referred to as “major regulations” as of September 2023).

 

  1. North Korea and Iran-related regulations

Trade regulation

  • Import and intermediary trade transactions of goods originating in or shipped from North Korea
  • Intermediary trade of goods destined to North Korea

 

Regulations on transactions with persons subject to sanctions

  • Payment to an individual with a domicile or residence in North Korea or to a juridical person, etc. with a principal office in North Korea (including payment to a juridical person, etc. under substantial control of the individual or juridical person)

 

Regulations on the Purpose of Remittance

  • Payment to an individual with a domicile or residence in North Korea or to a juridical person, etc. with a principal office in North Korea (including payment to a juridical person, etc. under substantial control of the individual or juridical person)

 

  1. Russian and Belarus-related regulations

Trade regulation

  • Export and import transactions originating and destined from Donetsk (self-named) or Luhansk (self-named)

 

Restrictions on foreign direct investment

  • Transactions related to foreign direct investment in a business conducted in Russia or a business conducted in a foreign country by a Russian juridical person, etc. (including a juridical person, etc. under substantial control of the said juridical person)
  • Payment for business activities in Russia of cooperatives, etc. established jointly by Japanese residents and other non-residents
  • Payment for business activities in foreign countries of partnerships, etc. established jointly by Japanese residents with Russian corporations, etc. (including corporations, etc. substantially controlled by Russian individuals or corporations, etc.)

 

Service Provision Regulations

  • Transactions relating to the provision of specified technology to individuals and corporations, etc. in Russia and Belarus
  • Transactions relating to the provision of technology to specified organizations in Russia and Belarus designated under the Foreign Exchange and Foreign Trade Law
  • Transactions related to the provision of labor or benefits pertaining to trust business to individuals or corporations, etc. in Russia
  • Transactions relating to the provision of labor or benefits related to accounting, auditing, management consulting, construction and engineering to Russian corporations, etc.

 

Securities trading regulations

  • Transactions related to the acquisition or transfer of securities issued by the Russian government or other governmental organizations
  • Transactions relating to the issuance or offer for subscription of securities in Japan (including the provision of labor or services incidental thereto) by the Government of Russia or other governmental organizations, etc.
  • Transactions relating to the issuance or offer for subscription of securities in Japan (limited to those with a maturity of more than 30 days, if any) by a specified Russian bank (including an association in which the said bank directly owns at least 50% of the total number of shares/total amount of capital contribution) including the provision of labor or services involved therein;

 

Price ceiling regulation

  • Among transactions pertaining to a monetary loan contract or debt guarantee contract with a non-resident by a resident in Japan, transactions pertaining to the purchase or transport of Russian crude oil or petroleum products to be transported by sea (limited to transactions where the purchase price exceeds the maximum price)

 

  1. Others

Regulations on transactions with persons subject to sanctions

  • Payment, etc. with terrorists and others subject to economic sanctions such as asset freeze designated under the Foreign Exchange Act (hereinafter referred to as “those subject to sanctions”) (including payment with an organization in which a specified person subject to sanctions in Russia and Belarus directly holds 50% or more of the total number of shares/total amount of investment)
  • (*) is also subject to regulation in the following cases.
  • Payment, etc., made, directly or indirectly, on behalf of a person subject to sanctions (including payment, etc., made, on behalf of a person subject to sanctions, in the name of a third party)
  • Payment, etc. with Juridical Persons, etc. Substantially Controlled by Those Subject to Sanctions

 

Restrictions on foreign direct investment

  • Payment for business activities in foreign countries of cooperatives, etc. related to fisheries, leather or leather products, arms, arms production facilities, drugs, etc.

 

JRF Compliance Team

October 5, 2023

 


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