On September 3, 2010, the Government of Japan announced new sanctions against Iran to implement United Nations Security Council (UNSC) resolution 1929. [1] These new sanctions, which expand upon measures taken by the Japanese Government on August 3, seek to halt new investment in the Iranian energy sector and freeze the assets of entities linked to nuclear activities.

Under the authority of the Japanese Foreign Exchange and Foreign Trade Act, Japan will freeze the assets and ban the travel of 88 entities and 24 persons [2] who are believed to contribute to Iran's nuclear activities. It will also freeze the assets of the Islamic Republic of Iran Shipping Lines (IRISL). [3] Japan's measures also re-state its commitment to a strict export controls policy on Australia Group- and Wassenaar-listed items with regard to Iran.

Japan has ordered that the assets of 15 Iranian banks be frozen, that all correspondent banking relationships with the designated institutions be terminated and that no new correspondent accounts or relationships be established with any Iranian bank. [4] Funds transfers between Japan and Iran which relate to Iran's nuclear activities or Iran's activities pertaining to the supply of large conventional weapons are prohibited, and financial institutions are obliged to scrutinize transactions accordingly and report monthly on all Iran-related transfers. Under the measures, Japanese companies are prohibited from providing insurance or reinsurance services (if the activities covered could contribute to Iran's nuclear activities or supply of large conventional weapons). Further, Japanese financial institutions are prohibited from opening branches or subsidiaries in Iran, and vice versa. [5]

In the energy sector, the Government of Japan will halt all new oil and gas-related investment in Iran by refraining from entering into new medium to long-term commitments for export credit for trade with Iran. Japanese oil and gas-related associations are required to refrain from all new oil and gas projects as well, such as those involving the exploration and development of refining capacity. [6]

Notably, the new sanctions do not affect Japan's significant imports of crude oil from Iran, although financing such transactions in the absence of correspondent relationships is apt to become substantially more complex.