Remittance Restrictions Based on the Foreign Exchange and Foreign Trade Act and U.S. OFAC Regulations

Our company strictly complies with all applicable economic sanctions laws and regulations, including the economic sanctions regulations under Japan's "Foreign Exchange and Foreign Trade Act," as well as regulations administered by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury. Accordingly, we do not accept any transactions that conflict with (or carry the risk of conflicting with) these laws and regulations.

Please confirm that your remittance is completely unrelated to any of the following transactions.

1. Economic Sanctions Against North Korea and Iran

Regulations on Payments Related to Trade with North Korea
・Transactions conducted for the purpose of contributing to "activities that may support North Korea's nuclear-related programs, etc."
・Transactions related to intermediary trade involving cargo destined for North Korea.

Restrictions on the Use of Funds for North Korea
・Transactions related to the import or intermediary trade of all goods originating from or shipped from North Korea.

General Prohibition on Payments to North Korea
・Transactions conducted for the purpose of contributing to "activities related to the supply of large conventional weapons to Iran, etc."

Restrictions on the Use of Funds for Iran
・Transactions conducted for the purpose of contributing to "activities that may support Iran's nuclear-related activities, etc."
Purchases of items that are prohibited from import or that require import licenses, approvals, certifications, notifications, etc.

2. Economic Sanctions Related to the Situation in Ukraine

Payments to Entities More Than 50% Owned by Specific Organizations
・Entities that are more than 50% directly owned (in terms of total shares or capital contributions) by Russian or Belarusian organizations subject to asset freeze measures (excluding the Central Bank of Russia).

Regulated Transactions Related to the Issuance of Securities
(1) Acquisition or transfer of securities issued by the Russian government or other governmental institutions.
(2) Issuance or offering of securities in Japan by the Russian government or other governmental institutions.
(3) Issuance or offering in Japan of securities (limited to those with a maturity of more than 30 days) by designated Russian banks or by entities that are more than 50% directly owned by such banks (excluding entities with their principal offices in Japan).
(4) Provision of labor or services for the purpose of facilitating the issuance or offering of securities as described in items (2) and (3) above.

Regulated Transactions Related to Technology Provision and Services
(1) Provision of technology related to export bans targeting residents of Russia or Belarus (limited to transactions initiated on or after March 18, 2022; excludes provision of publicly available technology. This also applies to item (2) below).
(2) Provision of technology to designated entities in Russia or Belarus.
(3) Provision of trust-related services or benefits to residents of Russia (limited to transactions initiated on or after September 5, 2022; excludes provision to corporations or other entities in which Japanese residents hold 10% or more ownership or have a continuous economic relationship with Japanese residents. This condition also applies to item (4) below).
(4) Provision of accounting, auditing, or management consulting services to Russian corporations or equivalent entities.
(5) Provision of architectural or engineering services to Russian corporations or equivalent entities.
(6) Among the transactions in item (3), any occurrence, change, or termination of claims under a trust agreement with a Russian resident (limited to cases where the Russian resident is the trustor) is separately regulated as a capital transaction.

Regulated Transactions Related to Foreign Direct Investment (FDI)
(1) Foreign direct investment related to business operations conducted in Russia (limited to investments initiated on or after May 12, 2022; same applies below).
(2) Foreign direct investment related to business operations conducted outside of Russia by Russian corporations or corporations effectively controlled by Russian corporations.
Note: The following are subject to FDI regulations — acquisition of securities, loans, and payments for the establishment or expansion of branches, factories, etc., made for the purpose of establishing a continuous economic relationship with a foreign corporation, such as in cases where the investment results in an ownership ratio of 10% or more. Additionally, payments equivalent to items (1) and (2) made by residents to partnerships or other entities jointly established with non-residents are also subject to regulation.

Regulations on Capital Transactions Related to the Price Cap on Russian Crude Oil or Petroleum Products
・Prohibition of transactions involving the creation of claims under loan agreements or debt guarantee contracts related to the importation of crude oil or petroleum products of Russian origin transported by sea, if such imports exceed the established price cap.

③ Prohibited Transactions under U.S. OFAC (Office of Foreign Assets Control) Regulations

Payments to designated individuals/entities on the SDN List (Specially Designated Nationals and Blocked Persons List), etc.
・Payments to terrorists designated by the U.S. government, drug trafficking organizations, individuals/entities involved in the proliferation of weapons of mass destruction, and governments/affiliated agencies of sanctioned countries (such as Russia, Belarus, North Korea, Iran, Cuba, Syria, etc.), as well as entities substantially controlled by them.

Payments and fund transfers related to comprehensively sanctioned countries and regions designated by the U.S. (*)
・Transfers of funds involving residents or government officials of the relevant countries/regions, or general transactions originating from, bound for, or transiting through these areas (including indirect remittances and transactions using third-party names). ( * ) Cuba, Iran, North Korea, Syria, and Russian-occupied regions of Ukraine (Crimea, Donetsk, Luhansk, Zaporizhzhia, and Kherson regions), etc.

Transactions intended to evade or circumvent U.S. OFAC regulations
・Payments made through the U.S. dollar settlement system (U.S. financial system) that conceal or disguise prohibited acts under OFAC regulations or transactions with sanctioned parties.