The Japanese government introduced further sanctions against Russia on 6 February 2023.

These are in relation to oil products of Russian origin which are bought at a price that exceeds the ceiling price referenced in the MOFA (Ministry of Foreign Affairs 20230206外務省告示 ( notice dated 6 February 2023. In relation to these products the Japanese government has been taking the following measures from 6 February 2023 based on the Foreign Exchange and Foreign Trade Act:

Import ban on oil products of Russian origin which are bought at a price exceeding the ceiling price

The oil/oil products that are bought above the ceiling price should obtain a permission from the Ministry of Economy, Trade and Industry (“METI”); and

The oil/oil products that are bought at or below the ceiling price should be confirmed in advance by METI.

(NOTE) These measures are apply to relevant oil products that are imported on or after the 6th of February 2023, unless the import is based on a contract which was concluded prior to 6 February 2023,  the goods were loaded before 6 February and unloaded before 1 April 2023.

Ban on providing services in relation to the purchase of oil products of Russian origin that have been bought at a price exceeding the ceiling price

From 6 February 2023 a licence should be obtained for the provision of loan agreements, debt guarantee contracts, debts offsets etc. related with the purchase of oil products which are of Russian origin and which are bought at a price exceeding the ceiling price and for the provision of services which are designated in the notice the Ministry of Finance (“MOF”) (KO-20230206-100.pdf ( and the METI (20230206ekimu.pdf (, including brokerage transactions.

(NOTE) This measure applies when the implementation of debts or provision of labour or service happens on or after 6 February 2023, unless the transactions which are based on the contract concluded prior to 6 February 2023 and are related to the purchase of oil products of Russian origin which are loaded prior to 6 February 2023 and unloaded in Japan prior to 1 April 2023.

Read our previous blogs on earlier sanctions imposed by the Japanese government here, herehereherehereherehereherehereherehereherehereherehere and here.

To view Japan’s lists of currently designated persons/entities, click on these links: Russian FederationSpecially designated banks in the Russian FederationRussian government and its governmental organizations subject to prohibition of issuance or subscription of securities, Russian Specially Designated entities (1),  (2)(3),  (4),  , and (6). Belarusian Specially Designated entities (1) and (2)Crimea, Donetsk People’s Republic and Luhansk People’s Republic, and Republic of Belarus.



外務省告示(2月6日告示)(20230206外務省告示 ( )により指定された上限価格を超える価格で取引されるロシア連邦を原産地とする石油製品について,外国為替及び外国貿易法に基づく次の(1)及び(2)の措置を2月6日から実施する。

(1) 上限価格を超える価格で取引されるロシア連邦を原産地とする石油製品の輸入禁止措置


  (注)令和5年2月6日以降に行われる輸入について適用する。ただし,同日より前に輸入に係る契約を行った者がその契約に基づいてする輸入であって,同日より前に船積みされ,我が国において令和5年4月1日より前 に船卸しされるものについては,適用しない。

(2) 上限価格を超える価格で取引されるロシア連邦を原産地とする海上において輸送される石油製品の購入等に関連するサービスの提供の禁止措置

  上限価格を超える価格で取引されるロシア連邦を原産地とする海上において輸送される石油製品の購入等に関連する,金銭の貸付契約,債務の保証契約及び債務の相殺等並びに財務省告示(KO-20230206-100.pdf ( 及び経済産業省告示(20230206ekimu.pdf ( で定めるサービスの提供(仲介貿易取引を含む。)を許可制とする。








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Junko focuses her practice on commercial and trade laws and regulations, WTO dispute settlement, civil and criminal litigation, antitrust law, bankruptcy law and general corporate law. She has extensive experience advising clients on issues involving trade remedy matters such as anti-dumping and countervailing duties, and import restrictions. She also advises on customs matters, classification and valuation issues, export control and sanctions, tariff treatment, FTA/EPA applications, public procurement, and handles antitrust compliance programs for clients.