金融行动特别工作组-日本在加强打击洗钱和资助恐怖主义措施方面取得的进展（英）-2023.10-36页_993kb

报告摘要

Anti-Money Laundering and Counter-Terrorist Financing Measures: Japan's 2023 FATF Follow-Up Report

Background

Japan was placed in enhanced follow-up after its 2021 Mutual Evaluation Report (MER). This second Enhanced Follow-Up Report (EFUR) reviews Japan's progress since the adoption of the MER in June 2021, with technical compliance re-ratings adopted by the FATF Plenum in October 2023.

Key Findings

Japan has made progress in addressing technical compliance deficiencies, leading to upgrades on specific FATF Recommendations.
Five Recommendations were re-rated: R.5, R.6, R.8, R.24, and R.28.
Recommendation R.25 remained partially compliant.
Overall, Japan has partially addressed deficiencies, but some issues persist, particularly concerning non-profit organizations (NPOs), legal persons' beneficial ownership, and terrorist financing.

Re-Ratings Summary

Below is a table summarizing the FATF Recommendations re-rated in this report:

FATF Recommendation	Previous Rating	New Rating	Summary of Progress
R.5 (Terrorist Financing Offence)	Largely Compliant	Largely Compliant*	Criminalisation of financing updated; sanctions increased for direct TF. Not fully compliant due to gaps in self-funding applications.
R.6 (Targeted Financial Sanctions)	Largely Compliant	Largely Compliant*	Sanctions timelines improved; enhanced procedures for nominations and asset freezing, but scope gaps remain.
R.8 (Non-Profit Organizations)	Partially Compliant	Partially Compliant*	Outreach and guidelines added, but NPO oversight remains limited, and risk assessments not fully risk-based.
R.24 (Beneficial Ownership)	Largely Compliant	Largely Compliant*	BO information improved; gaps persist in scope and timeliness for associations/foundations.
R.28 (Regulation of Casinos/DNFBPs)	Largely Compliant	Largely Compliant*	Casino framework established; DNFBP supervision enhanced, but risk-based oversight not fully implemented.
R.25 (Civil Trusts)	Partially Compliant	Partially Compliant*	No significant changes; gaps in trustee obligations and information disclosure remain.

*: Based on increased severity of sanctions and policy updates since the MER.

Persistent Issues

Deficiencies in R.8, R.24, R.25, and others related to NPO oversight, legal persons' transparency, and terrorist financing remain, though considered minor due to Japan's context.

Conclusion

Japan has demonstrated progress in strengthening its AML/CTF framework, but further efforts are needed to address outstanding technical compliance deficiencies. Japan must report back on implementation progress to the FATF in October 2024.

展开完整摘要