Economic Security · AML/CFT · Real Estate

Compliance for the Japanese market, made simple.

From the Act on Prevention of Transfer of Criminal Proceeds (APTCP / 犯収法) to inward-investment review under FEFTA and the Important Land Survey Act — JustAML brings AI to AML and economic-security compliance for real estate businesses.

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APTCP
Specified-operator duties
Enhanced
FATF follow-up status
700K+
Suspicious reports / year
7 yrs
Record-retention duty
Japan-Ready Modules
  • ✓Identity verification (KYC / KYB)
  • ✓Sanctions, PEP & adverse-party screening
  • ✓Beneficial-owner (BO) verification
  • ✓FEFTA inward-investment review support
  • ✓Important Land Survey Act eligibility checks
  • ✓Suspicious-transaction reports (evidence pack)
  • ✓Ongoing customer management & recordkeeping
Recognised By 21–24 HKSTP IncuTech 2021 CityU Tech 300 2022 ETNet FinTech – RegTech 2023 HKABA Innovation
Why It Matters

AML and economic security are now being tested at the same time

In the FATF Fourth-Round Mutual Evaluation, Japan was placed under "enhanced follow-up." Supervision has tightened, and expectations of specified business operators — real estate first among them — keep rising.

🌐
Pressure from FATF
The FATF Fourth-Round Mutual Evaluation of Japan (August 2021) placed the country under "enhanced follow-up." Tighter FSA guidelines and a government action plan are now in progress.
📈
Reports at record highs
Suspicious-transaction reports from specified operators exceed 700,000 a year. Box-ticking checks alone can no longer surface the real risks.
🏢
Real estate is high-risk
High-value, cash-based and complex fund flows make property deals a persistent money-laundering vulnerability — as flagged repeatedly in the National Risk Assessment.
⚠️
Economic security
FEFTA inward-investment review and the Important Land Survey Act have made background screening of foreign investment and land acquisition a new compliance duty.
Enh.F-up
FATF 4th-Round Evaluation of Japan (2021)
700K+
Suspicious-transaction reports (annual, recent)
7yrs
Verification & transaction record retention
¥3M
Max. fine for identity-verification breaches (＋ up to 2 yrs imprisonment)
Understanding the APTCP

What is the Act on Prevention of Transfer of Criminal Proceeds (犯収法)?

The APTCP is the cornerstone of Japan's AML/CFT regime. It requires "specified business operators" — including real estate brokers (宅地建物取引業者) — to verify customers at the time of transaction, keep records, and file suspicious-transaction reports.

2007
APTCP enacted
Enacted to counter organised crime and terrorist financing, and fully in force from 2008 — imposing identity-verification, recordkeeping and reporting duties on financial institutions.
2011 & 2016 amendments
Verification tightened
Introduced beneficial-owner verification, checks on the purpose of the transaction and the customer's occupation, and enhanced due diligence (EDD) for high-risk transactions.
2021
FATF 4th-Round Evaluation
Japan was placed under "enhanced follow-up." Full implementation of the FSA guidelines, more sophisticated ongoing customer management, and a genuine risk-based approach are now expected.
Ongoing
Converging with economic security
Under FEFTA and the Important Land Survey Act, background screening of foreign investment and land acquisition now overlaps with AML as a new compliance frontier.
Core duties of specified operators
01
Verification at transaction (KYC)
Confirm identity, purpose of the transaction and occupation/business — plus the beneficial owner for corporate customers.
02
Create & retain records
Prepare verification and transaction records and retain them for seven years after the transaction ends.
03
Suspicious-transaction reports
File suspicious transactions with JAFIC via the competent administrative authority.
04
Risk assessment
Assess and mitigate your own risks in light of the National Risk Assessment on the transfer of criminal proceeds.
05
Internal controls & training
Appoint a supervising manager, maintain internal rules, and provide staff education and training.
06
Ongoing customer management
Keep customer information current and monitor transactions on a continuing basis.
Economic Security · Foreign-Investment Review

Screening foreign investment and land acquisition through a security lens

This is the new mandate. Under FEFTA inward-investment review and the Important Land Survey Act, investment in Japanese assets by foreign individuals and entities is now subject to background screening from a national-security and information-security standpoint.

FEFTA (Inward-Investment Review)

Security screening at the point of entry

  • The 2020 amendment lowered the prior-notification threshold for listed companies from 10% to 1%.
  • "Core sectors" — weapons, aircraft, space, nuclear power, cybersecurity, electricity, gas, telecoms, railways and more — face intensive review.
  • The Ministry of Finance and competent ministries screen for national-security concerns, with designated sectors now covering a broad swath of listed firms.
  • Where concerns arise, measures such as orders to suspend or divest shares are available.
Important Land Survey Act

Regulating security-sensitive land

  • Passed in 2021 and fully in force from September 2022; land within roughly 1 km of defense, Japan Coast Guard and nuclear facilities, plus remote border islands, is designated as a "Monitored Area."
  • Command-function bases and remote border islands are designated "Special Monitored Areas."
  • In Special Monitored Areas, sales of land or buildings of 200 m² or more require prior notification.
  • The government may investigate owners' names, nationalities and use, and issue recommendations or orders against uses that impair national security.
Monitored Area
Roughly a 1 km radius around defense, Japan Coast Guard and nuclear-related facilities, plus remote border islands. The government may investigate the owners and use of land and buildings.
Special Monitored Area
Areas of particular security importance (command-function bases, remote border islands). Sales of land or buildings of 200 m² or more require prior notification of the name, address and intended use.
🆕 A new development: reviewing the rules on land acquisition by foreigners
The government is examining how the rules on land acquisition by foreign individuals and entities should be framed. On the ground, understanding a buyer's nationality, beneficial owner and intended use matters more than ever. Building your screening playbook now — ahead of tighter regulation — sharply reduces a business's exposure.
🔐 The information-security dimension
Telecommunications, data-related businesses and cybersecurity are "core sectors" subject to strict FEFTA review. Knowing your counterparty and their ultimate beneficial owner directly reduces the risk of technology leakage and information breaches. AML and economic security are bound by the same principle: Know Your Counterparty.
Real-Estate Focus

Dual due diligence, built for real estate businesses

Real estate brokers are "specified business operators" under the APTCP. On top of that, the Important Land Survey Act and FEFTA make verifying a buyer's nationality, background and source of funds more important than ever.

🪪
Buyer & seller KYC
Verify individuals and entities — and confirm the beneficial owner (BO) of corporate parties — in seconds.
Transaction verificationBO check
  • OCR and automated validation of ID documents
  • Background screening of foreign buyers and entities
  • Enhanced due diligence (EDD) for high-risk deals
💴
Source-of-funds & payment monitoring
Detect suspicious fund flows — cash, multiple payers, cross-border remittances.
Transaction monitoringSource of funds
  • Threshold alerts for high-value and cash transactions
  • Detection of overseas remittances and third-party payments
  • Auto-built evidence packs for suspicious-transaction reports
🛡️
Security-sensitive land checks
Check whether a property falls within a Monitored or Special Monitored Area and support prior notification under the Important Land Survey Act.
Important Land Survey ActPrior notification
  • Zone-eligibility workflow
  • Decision support for the 200 m² notification trigger
  • Foreign-buyer flags and recording of intended use
🌏
Foreign-capital background screening
Match against sanctions, PEP and adverse-media sources in multiple languages to surface economic-security risk.
Sanctions & PEPFEFTA
  • UN, OFAC, EU and Japanese sanctions-list matching
  • Relevance checks against core and designated sectors
  • Adverse-media research in Japanese and other languages
🗂️
Recordkeeping & audit readiness
Store verification and transaction records securely for seven years, with a tamper-proof audit trail.
7-year retentionAudit trail
  • Automatic retention of verification and transaction records
  • One-click export for regulatory inspection and internal audit
  • Advance alerts for document-expiry dates
🔁
Ongoing customer management
Keep customer risk profiles current and re-screen instantly whenever sanctions lists are updated.
Continuous monitoringRe-screening
  • Automatic re-matching on sanctions-list updates
  • Automatic alerts on risk changes
  • A compliance calendar for periodic reviews
Enforcement & Sanctions

The cost of non-compliance

Regulators — the National Police Agency/JAFIC, the FSA, the Ministry of Finance and the MLIT — are stepping up supervision and correction. The following illustrate the types of measures available under Japanese law.

Real Estate Broker
Correction for verification-duty breaches
Where a broker fails to verify identity or the beneficial owner in a high-value deal and keeps inadequate records, it may face correction and supervisory measures from the competent authority.
⚖️ Corrective order + business suspension (Brokerage Act)
APTCP (Criminal Penalty)
Breach of verification / recordkeeping duties
A breach of transaction-verification or recordkeeping duties may, following a corrective order that is then disobeyed, become subject to criminal penalties.
⚖️ Up to 2 yrs imprisonment or a fine up to ¥3M
FEFTA (Inward Investment)
Failure to file prior notification
Where foreign capital invests in a designated sector — including core sectors — without the required prior notification, it may be subject to review and measures on national-security grounds.
⚖️ Suspension / share-divestment orders / penalties
Important Land Survey Act
Failure to file prior notification
Failing to file prior notification for a sale of 200 m² or more in a Special Monitored Area may draw penalties, with recommendations or orders issued against security-impairing uses.
⚖️ Recommendations / orders / penalties
Why JustAML

Compliance without complexity

JustAML takes on the intricate verification work so you can focus on your core business.

⚡
Instant verification
Complete individual and corporate KYC/KYB in seconds — no manual data entry, no waiting.
🤖
AI-powered background screening
Match sanctions, PEP and adverse media in Japanese and other languages, cutting false positives.
🛡️
Built for economic security
Surface FEFTA core-sector relevance and Important Land Survey Act zone eligibility at a glance.
🏢
Optimised for real estate
Workflows for real estate brokers, with seven-year record retention built in.

Enable the simplicity of regulatory compliance!

JustAML — AML and economic-security compliance for the Japanese market, on a single platform.

Contact See Economic-Security Tools

Note: This page is provided for general information about the Act on Prevention of Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act (FEFTA), the Important Land Survey Act and the FATF Fourth-Round Mutual Evaluation of Japan, and does not constitute legal advice. Statistics and the types of enforcement shown are illustrative and do not refer to any specific case. Please confirm the latest laws and guidelines, and consult a qualified professional as needed, before acting.

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