Curfex

Sanctions Guide

As a funds transfer operator, Curfex shall ensure the implementation of economic sanctions as dictated in the Foreign Exchange and Foreign Trade Act ('Foreign Exchange Act') in the remittance transfers that we process. Pursuant to the provisions of Article 17 of the Foreign Exchange Act, we endeavour to ensure that our customers' remittance transfers are NOT subjected to regulations on payment restrictions.


  1. You will be required to make a declaration (in the transfer confirmation page) as follows:

    1. Your transfer is NOT subjected to regulations on payments restrictions based on the Foreign Exchange Act.
    2. This transfer is NOT related to North Korea, Iran, Russia and/or Belarus.
    3. The final beneficiary of the transfer is NOT a resident of North Korea and/or an entity effectively controlled by residents of North Korea.
    4. The beneficiary of the transfer is NOT an entity in which 50% or more of the total number of shares is directly held by entities subject to sanctions in Russia or Belarus
  2. You will be required to declare your purpose of transfer.
    1. If the purpose of transfer is import payment, intermediary trade payment, or similar, you will also be required to provide us with the product/goods, place of origin (country), shipping region (city), destination (country) (in the case of an intermediary trade payment).
    2. If the purpose of transfer is investment, you are required to confirm if it involves the following industries:
      1. Fishery (the business of catching aquatic animals and plants)
      2. Manufacturing of leather or leather products
      3. Manufacturing of weapons or equipment related to weapons
      4. Manufacturing of narcotics/drugs
  3. You may be required to present documents to proof and confirm the details of the transfer. When required, we may ask you to send us documents to proof and confirm the details of the transaction. If it cannot be confirmed conclusively that your transfer is NOT a restricted payment, we reserve the right to reject the transfer.
  4. For details on the scope of specific regulations, please refer to the relevant Ministry of Finance notices and the Ministry of Finance website.

Regulations on payments based on the Foreign Exchange Act (Restricted Payment Excerpt - as of July 18, 2024)


  1. Related to North Korea

    1. To North Korean residents or legal entities/organizations substantially controlled by such residents
    2. Transactions, etc. conducted for the purpose of contributing to activities that may contribute to North Korea's nuclear-related programs, etc.
    3. Import of goods originating or shipped from North Korea
    4. Intermediate trade of goods originating, shipped from or destined for North Korea
    5. Capital transactions or financial services, etc. conducted for the purpose of contributing to activities that may contribute to North Korea's nuclear-related programs, etc.

  2. Related to Iran

    1. Transactions, etc. conducted for the purpose of contributing to Iran's nuclear activities
    2. Acquisition of shares or equity stakes of companies operating in specific industries related to nuclear technology, etc. by Iranian parties (the Iranian government, non-residents with Iranian nationality, or corporations established under the laws of Iran, etc.) , including both inward direct investment and transfers of such shares or equity stakes to these parties that do not constitute inward direct investment

  3. Related to Russia/Belarus

    1. Acquisition or transfer of securities issued by the Russian government, etc.
    2. Issuance or solicitation of securities in Japan by the Russian government, etc. or specific Russian banks, etc., or service transactions for such issuance or solicitation
    3. Provision of technology related to export prohibition measures against residents of Russia and Belarus, etc.
    4. Provision of technology to specific organizations in Russia and Belarus
    5. Provision of technology to specific organizations outside Russia and Belarus
    6. Trust services with Russian residents, etc., or trust contracts entrusted by such persons
    7. Service transactions related to accounting, auditing, management consulting, architectural services, and engineering services for Russian corporations, etc.
    8. Outward direct investment in business conducted in Russia (including payments from Japan to a foreign country by a resident for business activities in Russia through a partnership or other entity jointly established by the resident with another person)
    9. Outward direct investment in business conducted in a foreign country by Russian entities, etc. and entities substantially controlled by Russian entities, etc. (including payments from Japan to a foreign country by a resident for business activities in a foreign country by a partnership or other entity jointly established by the resident with a Russian resident, a Russian company, etc., or other entities substantially controlled by them)
    10. Loan contracts or debt guarantee contracts related to the purchase or transportation of crude oil or petroleum products from Russia that are traded at prices exceeding the ceiling price
    11. Service transactions related to the marine transportation of crude oil and petroleum products from Russia that are traded at prices exceeding the ceiling price (issuance of letters of credit, etc.)