Publication of Public Comments on Draft Guidelines for Money Laundering, Terrorist Financing, and Proliferation Financing Measures for Certified Public Accountants and Auditing Firms

2026年7月20日

Japan has recently published draft guidelines aimed at combating money laundering and terrorist financing within the accounting and auditing sectors. This development is crucial for foreign entrepreneurs operating in Japan, as it highlights the government’s commitment to enhancing financial integrity and compliance. Understanding these guidelines is essential for businesses to navigate regulatory requirements and avoid potential legal pitfalls.

📋 Quick Summary for Foreign Business Owners
Category: Regulatory Update

Background & Context

The Financial Services Agency (FSA) of Japan has issued draft guidelines concerning measures against money laundering, terrorist financing, and proliferation financing specifically for certified public accountants and auditing firms. This initiative is part of Japan’s broader efforts to align its financial regulations with international standards, particularly those set by the Financial Action Task Force (FATF). The guidelines aim to strengthen the compliance framework for accountants, ensuring they implement effective risk management strategies. The regulatory landscape has evolved significantly, with the Act on Prevention of Transfer of Criminal Proceeds being a cornerstone of Japan’s legal framework since its enactment in 2007 and its amendments in subsequent years. The FSA’s latest draft was made public on July 20, 2026, inviting public comments to refine the guidelines further. This ongoing dialogue reflects Japan’s proactive stance in addressing financial crimes and enhancing the transparency of its financial systems.

How This Affects Your Business in Japan

Item	Cost (JPY)	Cost (USD approx)	Notes
Legal Consultation	¥50,000	~$350	Per session
Training Materials	¥100,000	~$700	Includes sessions
Translation Services	¥30,000	~$210	For guideline review

1. Foreign Residents Already Operating a Business in Japan
For foreign entrepreneurs currently running businesses, compliance with the new guidelines is essential to avoid penalties. They should review their existing anti-money laundering (AML) policies and ensure they align with the new requirements. This may involve updating internal procedures and training staff on compliance measures. Failure to comply could result in significant fines or legal action, so it is advisable to consult with legal experts specializing in corporate law in Japan.

2. Foreign Nationals Planning to Establish a New Company
For those looking to start a business in Japan, understanding these guidelines is crucial from the outset. They should incorporate AML compliance into their business plans and seek legal advice to ensure their operations meet the new standards. This includes establishing robust internal controls and reporting mechanisms. The risk of non-compliance can hinder business operations and lead to reputational damage.

3. Foreign Investors Who Are NOT Residents of Japan
Investors considering entering the Japanese market must be aware of these guidelines as they may affect investment decisions, especially in sectors like finance and real estate. Conducting thorough due diligence on potential investments and ensuring that target companies comply with AML regulations is vital. Investors should also consider the potential impact of these guidelines on the overall business environment in Japan, as non-compliance could lead to increased scrutiny and regulatory challenges.

Step-by-Step: What You Need to Do

Step 1: Review the Draft Guidelines
Obtain a copy of the draft guidelines from the Financial Services Agency (FSA) website. English support may be limited, so consider using translation services.
Office: FSA (English Support: Limited)
Cost: Free (¥0)
Time: 1 hour
Pitfall: Misinterpretation due to language barriers

Step 2: Assess Current Compliance
Evaluate your existing AML policies against the new guidelines. This may require consulting with a legal expert.
Office: Legal Consultant (English Support: Yes)
Cost: ¥50,000 (~$350 USD)
Time: 1-2 weeks
Pitfall: Overlooking minor compliance issues

Step 3: Update Internal Procedures
Revise your internal controls and reporting mechanisms to align with the new requirements. This may involve staff training.
Office: Internal Compliance Team (English Support: Yes)
Cost: ¥100,000 (~$700 USD)
Time: 2-4 weeks
Pitfall: Insufficient staff training

Step 4: Submit Comments
If you have feedback on the draft guidelines, prepare and submit your comments to the FSA before the deadline. Check the FSA website for submission details.
Office: FSA (English Support: Limited)
Cost: Free (¥0)
Time: 1 week
Pitfall: Missing the submission deadline

Step 5: Monitor Regulatory Changes
Stay informed about any final changes to the guidelines and adjust your compliance strategies accordingly.
Office: Internal Compliance Team (English Support: Yes)
Cost: Free (¥0)
Time: Ongoing
Pitfall: Failing to update compliance measures

Key Contacts
www.jetro.go.jp/en/
www.moj.go.jp/isa/
www.fsa.go.jp/en/

Expert Analysis: Japan vs. Regional Competitors

Metric	Japan	Singapore	Hong Kong	South Korea
Incorporation Time	14 days	3 days	5 days	7 days
Minimum Capital Requirement	¥1	S$1	HK$1	₩100
Corporate Tax Rate	23.2%	17%	16.5%	22%
Regulatory Compliance Cost	High	Moderate	Moderate	Low

What to Expect Next

As Japan continues to refine its regulatory framework, entrepreneurs and investors should keep an eye on the finalization of these guidelines and any subsequent amendments. The FSA is expected to release the finalized version by the end of 2026, which will provide clearer directives for compliance. Additionally, potential legislative changes aimed at further enhancing financial transparency may emerge in 2027, making it essential for foreign business owners to stay informed and proactive in their compliance efforts.