AML/CFT and Financial-Crime Compliance in Japan
We advise overseas businesses, Japanese companies and legal and compliance teams on Japanese anti-money laundering and counter-terrorist financing requirements, FATF standards, economic sanctions and related cross-border compliance issues.
Our work can include assessing how Japanese requirements apply to a business, reviewing internal policies and identifying gaps between global compliance arrangements and local requirements. The scope and deliverables are agreed for each engagement.
Matters You Can Discuss with Us
- Japanese requirements for customer due diligence and beneficial ownership.
- Risk assessments, transaction monitoring and suspicious-transaction controls.
- Review of AML/CFT policies for payments, financial and technology businesses.
- Foreign-exchange regulation, economic sanctions and cross-border compliance.
- Japanese-law questions for overseas counsel and in-house legal teams.
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Research and Publications
Ryu Nakasaki’s work includes books, translations and presentations on financial-crime prevention and international standards. The materials below are primarily in Japanese; English descriptions are provided to help readers identify relevant resources.
Latest Books
- Detailed Commentary on the Act on Prevention of Transfer of Criminal Proceeds — 9th edition, 2026 (Japanese).
- Detailed Commentary on the Foreign Exchange and Foreign Trade Act and Trade-Related Laws — 9th edition, 2026 (Japanese).
Other publications include an article-by-article commentary on the FATF Recommendations. View the attorney profile and publication list.
FATF Standards: June 2026 Materials
- Tentative Japanese translation of the FATF Recommendations and Interpretive Notes — June 2026 version.
- FATF Recommendations — English text on the FATF website (this source link may be updated by FATF).
- Abridged Japanese translation of the FATF Methodology — June 2026 version, technical compliance section.
- FATF Methodology — June 2026 source text.
- Changes between the October 2021 and June 2026 Japanese Methodology translations.
Earlier Versions and Further Resources
- FATF Recommendations: October 2025 Japanese translation.
- FATF Recommendations: June 2025 Japanese translation.
- Full Japanese AML/CFT resource index, including earlier versions and presentation materials.
- Japanese translations of US, EU and Chinese AML legislation and related materials.
- FATF mutual evaluation and follow-up report index (Japanese-language index).
Selected Presentations and Commentary
The following materials are in Japanese and reflect their stated dates.
- Proposed Revisions to FATF Recommendation 16 and Their Impact on the Payments Industry — April 25, 2024.
- Financial Institutions and Financial Crime Countermeasures — November 21, 2023.
- FATF Recommendations, Japanese Anti-Money Laundering Legislation and Further Challenges in Combating Crime — ACAMS presentation, March 3, 2023.
- Proposed EU Anti-Money Laundering Regulation and Directive: Implications for Japan — February 17, 2023.
- Identity and Trust from the Perspective of Crime Prevention — December 14, 2022.
- Information Sharing and AML under Japanese Law — response to an enquiry from Money Laundering Bulletin, November 22, 2022.
- Trusts and FATF Compliance — October 6, 2022.
Earlier Research and Translation Archive
The following links retain the earlier materials listed on this page. They are historical resources and should be read with their publication dates in mind. For the June 2026 FATF materials, use the links above.
FATF Mutual Evaluation Report on Japan and Issues concerning Revision of Relevant Laws such as the Criminal Proceeds Act (Main Presentation Materials for Academy for International Business Transactions Academic Conference on Nov. 7th, 2021) [Japanese]
Supplemental Materials [Japanese]
Comment regarding FATF’s RBA Guidelines on Virtual Asset Service Providers (VASPs) (Nov. 2, 2021) [Japanese]
Information on “System for Beneficial Owner List” Study Group (Held on Dec. 9, 2021) [Japanese]
Translations are provided for reference and their accuracy is not guaranteed. Please consult the source texts and obtain advice on the requirements applicable to your particular matter.
Ryu Nakasaki, Attorney at law(ryu@nakasaki-law.com)
Contact Us
For advice on a business or compliance matter, please provide a brief outline of the issue, the parties involved and any deadline through our enquiry form. We will review the matter and conduct a conflict check before confirming whether we can assist.
