Update: Japan introduces further sanctions against Russia

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

The new sanctions relate to oil products of Russian origin bought at prices exceeding the ceiling referenced in the MOFA (Ministry of Foreign Affairs) notice dated February 6, 2023. The Japanese government has been taking the following measures in connection with these products since February 6, 2023 based on the Foreign Exchange and Foreign Trade Act:

• Import ban on oil products of Russian origin bought at prices exceeding the ceiling

Import permission should be obtained from the Ministry of Economy, Trade and Industry (“METI”) for oil / oil products bought for prices above the ceiling.

Oil / oil products that are bought for prices at or below the ceiling should be confirmed in advance by METI.

These measures apply to oil and oil products imported on or after February 6, 2023 unless the import is based on a contract concluded prior to February 6, 2023 and the goods were loaded before February 6 and unloaded before April 1, 2023.

• Ban on providing services in relation to the purchase of oil products of Russian origin bought at prices exceeding the ceiling

From February 6, 2023, a licence should be obtained to conclude loan agreements, debt guarantee contracts, debts offsets, etc. related to the purchase of oil products of Russian origin bought at prices exceeding the ceiling and to provide services designated in the notice issued by the Ministry of Finance (“MOF“) and METI, including brokerage transactions.

This measure applies debt obligations incurred and labor or services provided on or after February 6, 2023, unless the transactions are based on contracts concluded prior to February 6, 2023 and related to the purchase of oil products of Russian origin loaded prior to February 6, 2023 and unloaded in Japan prior to April 1, 2023.