Terms & Policies

Requests relating to the Foreign Exchange and Foreign Trade Act and Economic Sanctions

Requests relating to the Foreign Exchange and Foreign Trade Act and Economic Sanctions

To comply with the domestic sanctions regulations (such as the Foreign Exchange and Foreign Trade Act of Japan ("FEFTA") as well as the international sanctions regulations imposed by the competent regulatory authorities, REVOLUT TECHNOLOGIES JAPAN, Inc. confirms that all client fund transfers do not constitute prohibited transactions under relevant sanctions.

As part of such confirmation, please kindly confirm and declare that your transactions do not fall under the restricted transactions listed below.

Please read and confirm the following notes:

  1. We may additionally confirm details regarding the purpose of the transfer, the substantial controller in the case of a legal entity, or other transaction details. We may also confirm your relationship with the recipient, as well as the recipient's date of birth and nationality.
  2. We will confirm that the transfer is not directed to restricted countries or regions. In particular, for foreign transfers related to imported goods, we will also verify product items, origin (country), shipment region (city), final destination (country), etc.
  3. Please ensure that the ultimate beneficiary of the transfer transaction (including substantial controllers in the case of legal entities) is not a North Korean resident (individual or entity).
  4. We may request transaction-related documents to verify the transaction details.
  5. We may request proof regarding the source of funds for the transfer.
  6. If you do not respond to our requests, or depending on the content provided, we may refuse to process your transaction.
  7. To properly fulfill requirements under the FEFTA and the Act on Prevention of Transfer of Criminal Proceeds, foreign exchange transfers on behalf of third parties (individuals or legal entities) cannot be processed.
  8. Please also check the following notes:

  [A] Regarding Compliance with FEFTA

  [B] Important Points Regarding US OFAC Sanctions Regulations

[A] Regarding Compliance with FEFTA

To reliably carry out confirmation obligations as a bank/service provider under Article 17 of the Foreign Exchange and Foreign Trade Act (FEFTA), we confirm that your transfer transactions do not fall under various regulations. For details and latest information on the restrictions under the FEFTA, please refer to the websites of the Ministry of Finance and the Ministry of Economy, Trade and Industry.

Ministry of Finance: List of economic sanctions and sanctioned partiesRegulatory ContentInformation related to Ukraine

Ministry of Economy, Trade and Industry

Payment Restrictions under FEFTA (Excerpt of North Korea, Iran, and Russia Regulations)

1. "Restrictions on Payments for Trade" involving North Korea

  • Transactions related to the import or intermediate trade of all kinds of goods whose place of origin or region of shipment is North Korea
  • Transactions related to the intermediate trade of goods whose destination is North Korea

2. "Restrictions on Payments for Specific Purposes" involving North Korea

  • Transactions conducted for the purpose of funding "activities that contribute to North Korea's nuclear projects"

3. Prohibition on payments to individuals/entities domiciled in North Korea

  • Including payments to entities substantially controlled by such individuals or entities

4. "Restrictions on Payments for Specific Purposes" involving Iran

  • Transactions conducted for the purpose of funding "activities that contribute to Iran's nuclear activities"

5. Investment Restrictions involving Iran

  • Acquisition or transfer to/from Iranian parties of shares or equities in domestic companies engaged in business activities where investment by Iran is prohibited

6. Trade Restrictions concerning Russia and Belarus

  • Import/export transactions originating from or destined for the self-proclaimed "Donetsk People's Republic" or "Luhansk People's Republic"

7. "Restrictions on Outward Direct Investment" concerning Russia

  • New outward direct investment to Russia
  • Payment of funds for business activities conducted in Russia or outside Russia with Russian companies involved

8. "Restrictions regarding Service Transactions" concerning Russia and Belarus

  • Service transactions (provision of technology, etc.) with respect to regulated transactions concerning Russia or Belarus

9. "Restrictions on Capital Transactions" concerning price caps on Russian crude oil, etc.

  • Loan or guarantee contracts for debts in relation to the purchase of maritime transported Russian crude oil, etc., which are traded at prices above the price cap

10. Securities Transaction Restrictions concerning Russia

  • Transactions related to the acquisition or transfer of securities issued by the Russian government or government agencies
  • Transactions related to the issuance or offering of securities in Japan by the Russian government or government agencies (including the provision of labor or services associated therewith)
  • Transactions related to the issuance or offering of securities in Japan (limited to those exceeding 30 days if a redemption date is set) by specified Russian banks (including entities directly owning 50% or more of total shares/capital)

Transaction Restrictions with Sanctioned Parties

Payments to economic sanction targets subject to asset freezing designated under FEFTA, such as terrorists (hereinafter "Sanctioned Parties") (including payments to entities in which specific Russian or Belarusian sanctioned parties directly own 50% or more of total shares/capital). The following cases are also subject to regulations:

  • Payments made substantially for Sanctioned Parties regardless of direct or indirect involvement (including payments made under third-party names for Sanctioned Parties)
  • Payments to entities substantially controlled by Sanctioned Parties

Outward Direct Investment in 5 Specified Industries Requiring Prior Notification to the Minister of Finance

Payments for overseas business activities of partnerships or entities relating to "fisheries, leather or leather product manufacturing, arms manufacturing, arms manufacturing equipment manufacturing, or narcotics manufacturing"

[B] Important Points Regarding US OFAC Sanctions Regulations

The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury imposes measures such as transaction prohibitions and asset freezing against countries, regions, individuals, and entities designated by the US for foreign policy and national security reasons; such regulations are referred to as OFAC regulations. We confirm that customer transactions do not fall under OFAC regulations from the perspective of US legal compliance. Even if direct senders or recipients are not sanctioned, if parties or locations related to the underlying transaction are sanctioned, the transfer transaction will also be subject to sanctions.

For example, the following transactions are subject to these regulations:

  1. Comprehensively sanctioned countries or regions (Iran, Cuba, North Korea, Crimea region of Ukraine, self-proclaimed Donetsk People's Republic, self-proclaimed Luhansk People's Republic) are involved in the location of transaction parties (generally importers/exporters, involved banks/shipping companies, consignees, transport vessels, senders/recipients, guarantee beneficiaries) or related transaction places (generally origin, shipment, destination, flag state, etc.), including governments and government officials of comprehensively sanctioned countries.
  2. Parties designated by the US government as specific terrorists, specific narcotics traffickers, specific weapons of mass destruction traffickers, or entities/individuals involved in non-proliferation concerns are involved in the transaction.
  3. US persons (including overseas branches/subsidiaries), US residents, or US entities/financial institutions/organizations (including US branches/subsidiaries of non-US entities/financial institutions) are involved.

If your transaction falls under or is suspected of falling under OFAC regulations, we will verify transaction details and, depending on the results, may cancel or suspend the transaction at our discretion.

Regarding the verification of transaction details, intermediary banks or correspondent US financial institutions may conduct separate independent investigations in addition to ours, so we ask for your cooperation. Please also note that if assets are frozen due to OFAC regulations, funds held for the transaction cannot be refunded.

In such cases, please be aware that you will need to take appropriate measures yourself, such as applying to OFAC for unblocking/unfreezing assets.

Additionally, other transactions may be prohibited or restricted under economic sanctions imposed by Japan, the US, or international organizations.

For further details on these economic sanctions, please refer to the US Department of the Treasury OFAC website.

If you have any questions, please contact us in the in-app chat.