Sanctions against Russia: first case of arrests for alleged violations

On 10 July 2024, Osaka Prefectural Police arrested the representative director of a trading company on suspicion of violating the Foreign Exchange and Foreign Trade Law for illegally exporting without government approval export-controlled items that are subject to sanctions against Russia (“Case”). This is the first arrest in Japan involving unauthorized exports to Russia after the invasion of Ukraine. In this alert, we provide an overview of Japan’s sanctions against Russia, the Japanese government’s response to circumvention of sanctions restrictions (so-called sanctions evasion) and the Japanese government’s enforcement of sanctions against Russia. We then analyze this Case and propose actions that companies should take.