In Japan, there were two major updates to its export control and sanction regime announced in the past few weeks.
1. Reimposition of Sanctions Against Iran
On 29 September 2025, Japanese government announced the reimposition of the following measures under the Foreign Exchange and Foreign Trade Act, in response to United Nations Security Council Resolution 2231based on which sanctions against Iran concerning its nuclear issue under United Nations Security Council Resolutions 1737, 1747, 1803, and 1929 are to be reimposed:
- Export Controls: Effective 29 September 2025, the notice by METI “Exportation of goods related to weapons of mass destruction to Iran based on United Nations Security Council Resolution 2231” were amended to reimpose the sanctions against Iran that had been lifted under UN Security Council Resolution 2231 in 2015. The export of goods listed in Item 2 and Item 4 of Appended Table 1 of the Export Trade Control Order to Iran, and the provision of technologies listed in Item 2 and Item 4 of the Appended Table of the Foreign Exchange Order, will require an export license. Without such a license, these exports are prohibited.
- Asset Freezing Measures: Based on the Ministry of Foreign Affairs notification (promulgated on 28 September 2025), 78 entities and 43 individuals that are designated as being involved in Iran’s sensitive nuclear activities and the development of nuclear weapon delivery systems are subject to the following regulations:
- Payment Restrictions: Payments to designated individuals and entities are subject to licensing requirements.
- Capital Transaction Restrictions: Capital transactions with designated individuals and entities—including deposit agreements, trust agreements, and loan contracts—are subject to licensing requirements.
- Investment Ban: As designated on the Ministry of Foreign Affairs notification (promulgated on 28 September 2025), investments by Iranian-related parties (i.e., individuals with Iranian nationality or entities established under Iranian law) in Japanese companies operating in sectors designated as related to nuclear technology are subject to the following controls:
- Capital Transaction Restrictions: Transfers of less than 1% of shares in listed companies to Iranian-related parties require prior license.
- Inbound Direct Investment: Acquisitions of 1% or more of shares in listed companies or unlisted companies by Iranian-related parties are subject to notification requirements and are, in principle, prohibited.
- Restrictions on Fund Transfers: As designated on the Ministry of Foreign Affairs notification (promulgated on 28 September 2025), payments made for the purpose of contributing to activities related to Iran’s sensitive nuclear activities, the development of nuclear weapon delivery systems, or the supply of major conventional weapons to Iran are subject to licensing requirements.
- Import ban on weapons and goods related to nuclear activities originating in or shipped from Iran: Imports of weapons and related materials (as listed in Item 1 of Appended Table 1 of the Export Trade Control Order) originating in or shipped from Iran, as well as goods designated in the Resolution as related to Iran’s nuclear activities (as listed in Item 2 of Appended Table 1, Item 3(2)(7) [limited to bellows valves made of corrosion-resistant materials for uranium hexafluoride], Item 3(2)(9) [limited to vacuum pumps used in uranium isotope separation equipment], and Item 4), requires an approval.
2. Expansion of the End User List
Effective 9 October 2025 (promulgated on 29 September 2025), the End User List, which identifies foreign entities suspected of involvement in the development of weapons of mass destruction (WMDs) and missiles, or conventional weapons, has been amended. This update follows the Cabinet Decision on 4 April 2025 to review Japan’s complementary export control measures under the Foreign Exchange and Foreign Trade Act (FEFTA), the Foreign Exchange Order, and the Export Trade Control Order.
The revised End User List now includes 835 entities—an increase of 87—across 15 countries and regions. While the list is not an embargo list, it is a key component of Japan’s catch-all control regime. If the end user of goods to be exported from Japan appears on the list, exporters must apply for an export license unless it is clearly evident that the goods will not be used in the development of WMDs and missiles, or conventional weapons.
