JFSA Enforcement Actions

Key dates

Early 2Q 2024

- JFSA previously indicated additional jurisdictions would be added to the travel rule scope, signaling the ongoing evolution of the jurisdiction list and the need for firms to monitor regulatory updates

July 2026

- JFSA publishes the finalized partial amendment to the designation of countries/regions under Articles 17-2 and 17-3 of the Order for Enforcement of the APTCP following public consultation, confirming five additional jurisdictions

03 August 2026

- The finalized amendment to the designation of countries and regions under Articles 17-2 and 17-3 of the Order for Enforcement of the APTCP takes effect; travel rule obligations for transfers to VASPs in the newly added jurisdictions become legally binding from this date

Suggested considerations

• Review and obtain the official Attachment to identify the five newly added jurisdictions and verify their exact legal names and any specific conditions attached to their designation.
• Update internal jurisdiction lists and travel rule mapping to reflect all currently designated countries and regions under Articles 17-2 and 17-3, including the newly added five jurisdictions, ensuring that this mapping is embedded in transaction routing and screening engines.
• Revise travel rule implementation procedures so that originator and beneficiary information is consistently transmitted for all transfers of cryptoassets and electronic payment instruments from Japanese VASPs to foreign VASPs located in designated jurisdictions, including the new additions.
• Confirm that no de minimis threshold is applied in practice to covered transactions and that systems are configured to send travel rule data regardless of transaction size when the counterparty is in a designated jurisdiction.
• Update customer and counterparty onboarding documentation and contractual terms for foreign VASPs in newly designated jurisdictions to reflect their status as travel rule counterparties and any data-sharing, security, and retention requirements.

What changed

• - Japan has finalized a partial amendment to the list of designated countries/regions under Articles 17-2 and 17-3 of the Order for Enforcement of the Act on Prevention of Transfer of Criminal...
• The amendment expands the set of foreign jurisdictions for which Japanese firms must apply travel rule obligations when transferring cryptoassets and electronic payment instruments to foreign VASPs,...
• For transfers of cryptoassets and electronic payment instruments from Japanese VASPs to foreign VASPs, travel rule obligations apply only when the counterparty VASP is located in a jurisdiction...
• Transfers to foreign VASPs in non-designated jurisdictions remain outside the Japanese travel rule transmission obligation, reflecting JFSA’s concern about regulatory ineffectiveness where equivalent...
• The amendment confirms that the travel rule applies to both cryptoassets (virtual assets, VAs) and electronic payment instruments, including stablecoins (SCs) handled by Cryptoasset Exchange Service...