Asset freezing


In light of the current conflict between Russia and Ukraine, the government has implemented various economic sanctions against Russia based on the Foreign Exchange and Foreign Trade Act of Japan (the Foreign Exchange Act). Japan's economic sanctions have been implemented in alignment with many western industrialised countries and regions (eg, the United States, the European Union and the United Kingdom), and consist of, among other things:

  • import and export restrictions;
  • the freezing of assets of certain individuals and entities; and
  • a prohibition on issuing or circulating certain securities.

This article outlines the sanctions against Russia that the government has introduced up to 21 March 2022 in relation to asset freezing.

Asset freezing

In addition to other sanctions, the government has applied asset freezing measures to certain designated individuals and entities related to Russia, Belarus, Donetsk and Luhansk. The list of designated individuals and entities has been expanded several times since it was first published on 26 February 2022. Since then, the following entities and individuals (collectively, sanctioned parties) have been newly designated:

  • 34 entities related to Russia and Belarus (including the Central Bank of the Russian Federation and VTB Bank);
  • 95 individuals related to Russia and Belarus (including the Russian president, the Belarusian president and a certain number of oligarchs); and
  • 54 individuals affiliated with Donetsk and Luhansk.

Under the asset freezing measures, the following acts may not be carried out in conjunction towards the sanctioned parties unless the Japanese government gives permission:

  • any payment to the sanctioned parties; and
  • any capital transaction with the sanctioned parties (eg, deposit, trust or loan agreements).


The Japanese sanctions are based on a complex system of subordinate legislation and governmental notices under the Foreign Exchange Act. The sanctions have been constantly amended and tightened almost daily. Depending on how the situation develops, additional sanctions against Russia in alignment with western countries can be expected. Businesses and individuals in Japan should keep abreast of any new developments and how the current and future economic sanctions may affect them.

For further information on this topic please contact Makoto Ohnuma, Alex Kuhlmann or Nanoka Hayakawa at Nagashima Ohno & Tsunematsu by telephone (+81 3 6889 7000) or email ([email protected], [email protected] or [email protected]). The Nagashima Ohno & Tsunematsu website can be accessed at