Japan FEFTA Penalties for Export Violations: Which Cases Carry 10, 7, or 5 Years

Hello, this is Ryuta Hamamoto from TIMEWELL.

"Up to 10 years in prison and a ¥1 billion fine." That is the figure you will see first if you look up penalties under Japan's Foreign Exchange and Foreign Trade Act (FEFTA), and METI's own introductory guidance puts the same numbers in its penalty box.¹ They are real, but they are the ceiling for one specific tier: goods and technology designated as particularly likely to be used for nuclear, chemical, or biological weapons or missiles. An unlicensed export of an ordinary listed item tops out at 7 years. Violating an export approval requirement, such as Japan's sanctions on Russia, tops out at 5. Corporate fines split the same way, at ¥1 billion, ¥700 million, or ¥500 million depending on the article.

So the useful question is not "how bad can it get?" but "which article does my transaction fall under?" That depends on what was shipped, where it went, and which license or approval was missing. In this piece I lay out the criminal penalties, administrative sanctions, and warnings under the current statute, which I checked on Japan's e-Gov legal database on October 29, 2026, and map typical violations to each tier. One practical note before we start: a June 5, 2026 amendment shifted the penalty articles down by one number, so older material cites different article numbers for the same rules. If you want a quick read on where your own program stands first, our free Export Compliance Check takes about two minutes.

Key points (as of October 29, 2026)

Criminal penalties for unlicensed exports and technology transfers under FEFTA come in three main tiers. WMD-related items carry up to 10 years of imprisonment and a ¥30 million fine (¥1 billion for corporations). Other listed items, and catch-all exports to destinations outside Group A, carry up to 7 years and ¥20 million (¥700 million for corporations). Group A inform violations and missing export or import approvals carry up to 5 years and ¥10 million (¥500 million for corporations). These are Articles 69-7, 69-8, and 72, and fines can rise to five times the value of the goods. Separately, METI can ban a violator from exporting for up to three years (Article 53), even for negligent violations and with no limitation period. In METI's FY2024 analysis, 69% of cases closed with a written report and there were no sanctions or warnings, but 59% of violations were found by customs in post-clearance audits.

FEFTA Penalties at a Glance (Statute as of October 2026)

The table below lists the FEFTA penalties relevant to export and import controls, heaviest first. Article numbers and penalties follow the version of the Act in force since August 12, 2026, which was still the current text on October 29, 2026.²

Tier	Typical violations	Article	Individuals	Corporations	Limitation period
WMD-related	Unlicensed export or transfer of goods and technology designated by cabinet order as particularly likely to be used for nuclear, chemical, or biological weapons or missiles	Art. 69-7(2)	Up to 10 years and/or ¥30 million	Up to ¥1 billion	7 years
Listed items and similar	Unlicensed export or transfer of items in rows 1 to 15 of Appended Table 1 of the Export Trade Control Order and the matching technology; unlicensed catch-all exports to destinations outside Group A; unlicensed brokering of controlled goods between foreign countries	Art. 69-7(1)	Up to 7 years and/or ¥20 million	Up to ¥700 million	5 years
Group A inform and approvals	Exporting to Group A without a license after an inform notice; exporting or importing without a required METI approval; taking controlled technology abroad on paper or media without a license	Art. 69-8	Up to 5 years and/or ¥10 million	Up to ¥500 million	5 years
Other serious violations	Exporting while under an administrative export ban; obtaining a license or approval by fraud; breaching license conditions; unlicensed payments to sanctioned parties; unreported inbound investment	Art. 70	Up to 3 years and/or ¥1 million	Same as individuals	3 years
Procedural violations	Refusing or falsifying reports; refusing on-site inspections; disobeying an order to follow the exporter compliance standards	Art. 71	Up to 6 months or ¥500,000	Same as individuals	3 years

Three things about this table. First, the fine amounts are only baseline caps. When five times the value of the goods or technology exceeds the listed amount, the ceiling becomes five times the value. Ship a ¥100 million machine without a license and the individual fine ceiling is ¥500 million, not ¥20 million. For expensive equipment, the headline numbers understate the exposure.

Second, imprisonment and fines can be imposed together, and attempted unlicensed exports of goods are punishable (Article 69-7(3)). Third, limitation periods come from Article 250(2) of the Code of Criminal Procedure: 7 years for offenses with a maximum of 10 years, 5 years for offenses with a maximum under 10 years, and 3 years for offenses with a maximum under 5 years.³ Article 72(2) applies the same periods to fines against corporations.

Criminal liability generally requires intent. An honest classification error rarely becomes a criminal case on its own, but the administrative sanctions I cover below can be imposed for negligence.⁴

About the renumbering. Act No. 30 of 2026, promulgated on June 5, 2026 and partly effective the same day, added a new Article 69-5 on sharing information with foreign enforcement authorities. The amendment is mainly about tighter screening of inbound investment and did not change the export penalties, but everything after it moved down one slot: the old Article 69-6 is now 69-7, and the old 69-7 is now 69-8.⁵ If an older guide cites "Article 69-6," it means today's 69-7.

The Act has been amended again since. Act No. 64 of 2026 (the amendment to the Financial Instruments and Exchange Act and the Payment Services Act, promulgated July 23, 2026) also changes FEFTA text; parts took effect on July 23 and August 12, and the rest are scheduled for April 1 and July 22, 2027. Comparing the June 5 and August 12 versions of the Act article by article on e-Gov, Articles 53, 69-7, 69-8, 70, 71, and 72 read identically. As of October 29, the export and import penalties have not changed.²

Which Violations Fall into Which Tier

Where a transaction lands in that table depends on three questions: is the item or technology on the control list, where is it going, and which license or approval was needed? Here are the points that trip people up most.

Listed items: 7 years, or 10 for the WMD-related subset

Exporting goods listed in rows 1 to 15 of Appended Table 1 of the Export Trade Control Order without a license breaches FEFTA Article 48(1) and falls under Article 69-7(1), up to 7 years. Providing listed technology without a license, abroad or to a non-resident in Japan, breaches Article 25(1) and lands in the same tier. That includes what Japan calls deemed exports: sharing controlled technology in Japan with a foreign employee or student who is a non-resident, or with a resident who falls into one of the "specified categories" of people under strong influence from a foreign government or similar party.¹ METI's FY2024 analysis also describes a company that stored controlled technology in a cloud service its overseas subsidiary could freely access, which METI said can count as providing technology.⁶

Brokering a sale that moves goods from one foreign country to another also needs a license when the goods are arms or items that may be used to develop weapons of mass destruction, and doing it without one falls in the same 7-year tier.⁷

The 10-year tier is narrower than the headlines suggest. It covers only goods and technology that a cabinet order designates as particularly likely to be used for nuclear weapons, military chemical or biological agents, or rockets and unmanned aircraft capable of delivering them. Most manufacturers' products are not in it, but whether yours are is something to settle during classification, not after shipment.

Catch-all controls: 7 or 5 years, depending on the destination

This is the most common misunderstanding I run into. People assume that because an item is not on the control list, a catch-all violation must carry a lighter penalty. For destinations outside Group A, that is wrong. Article 1(1) of the Export Trade Control Order defines the exports that need an Article 48(1) license as exports of the goods in the middle column of Appended Table 1 to the regions in its right-hand column. Row 16, the catch-all row, lists "all regions (excluding those in Appended Table 3)," that is, everywhere except Group A, the countries Japan treats as running strict export controls of their own. So once a row 16 item to a non-Group A destination triggers the end-use or end-user requirements, or METI sends an inform notice, the export needs the same Article 48(1) license as a listed item.⁸ Shipping without it falls under Article 69-7(1), up to 7 years.

The 5-year tier applies to Group A. Article 1(3) of the Order requires an Article 48(2) license to export row 16 items to Group A countries, and Article 4(2) waives it unless an inform notice has been received. METI says it applies the Group A inform requirement only when there is a risk of diversion to countries of concern.⁹ Exporting without a license after receiving such a notice falls under Article 69-8: up to 5 years, or ¥500 million for corporations. Technology follows the same pattern: under Article 17(2) of the Foreign Exchange Order, row 16 technology bound for Group A needs an Article 25(2) license.⁷

I should be upfront that the July 2026 version of this article put all catch-all violations in the 5-year tier. That was wrong for destinations outside Group A, and I have corrected it here. For how to check the catch-all requirements themselves, see list controls vs catch-all controls in Japan.

Approval violations: 5 years (Russia, North Korea, CITES)

Export approvals under Article 48(3) and import approvals under Article 52 sit outside the security list controls. Japan uses them for sanctions and for treaty obligations: exports of sanctioned goods to Russia, imports of goods originating in or shipped from North Korea (banned outright as a unilateral Japanese measure since October 14, 2006),¹⁰ and trade in CITES-listed plants and animals. Exporting or importing without approval falls under Article 69-8, up to 5 years or ¥10 million. A law firm's analysis of the first arrest under Japan's Russia sanctions places those violations in the same tier.¹¹

The scope of that approval requirement widened in October 2026. Following the cabinet understanding of October 2 on additional measures against Russia, an amendment to the Export Trade Control Order (Cabinet Order No. 325 of 2026) took effect on October 16. It added to the Russia-bound goods requiring approval (Appended Table 2-3, item 2-2) minerals such as gypsum and plaster, steel products, copper and aluminum products, gas turbines, and various gauges and instruments. A ban on exports to four specified entities in countries other than Russia and Belarus took effect at the same time. Performance of contracts concluded before October 2 is exempt if carried out before November 1. On October 9 the Ministry of Finance's Customs and Tariff Bureau told customs offices to check carefully whether approval is required and to carry out export post-clearance audits properly.¹² Exporting the newly added items to Russia without approval falls in the same Article 69-8 tier. The penalty did not change; the range of items needing approval did.

Most of METI's published cases, which I list below, are approval violations. A May 2026 METI document on trends in its trade control post-clearance reviews flags two misunderstandings that keep coming up.¹³ One is assuming the customs broker will point out any required approval. The document is blunt: when goods are exported or imported without approval, it is the exporter or importer, not the broker, who is liable under FEFTA. The other concerns the small-value exemption. Whether it applies depends on the total contract value, not the value declared on each shipment, and METI notes that split shipments are regularly caught in customs post-clearance audits.

Exporting during a ban or obtaining a license by fraud: 3 years; refusing reports or inspections: 6 months

Article 70 carries up to 3 years of imprisonment or a ¥1 million fine (or up to three times the value of the goods if that is higher). On the export side, it covers exporting while under an administrative ban, taking an officer role that a sanction prohibits, obtaining a license or approval by deception or other wrongful means, and breaching the conditions attached to a license. Unlicensed payments to sanctioned parties and unreported inbound investment fall under the same article, which is why a headline saying "FEFTA violation" may be about money rather than cargo.

Article 71 carries up to 6 months or a ¥500,000 fine for failing to report or reporting falsely to METI and for refusing on-site inspections. It also applies when a company that exports controlled items ignores the exporter compliance standards, then ignores METI's recommendation, and finally disobeys METI's order.¹

Classification and catch-all records decide which tier applies: As the sections above show, the same item can fall under different articles depending on whether it is listed, whether the destination is in Group A, and whether an inform notice was received. In a post-clearance review, the first thing METI looks at is who made those calls and on what evidence. We publish a free template pack built from METI's published forms and the statutory text on e-Gov: classification and non-applicability certificate forms with a guide in Word, and an Excel set that includes a catch-all check sheet and a classification log. The forms are in Japanese, since that is what Japanese customs and counterparties expect. Download the 2026 classification template pack (free; registration with your company name and work email is required).

Administrative Sanctions and Warnings: A Separate Track

The criminal numbers get the attention, but in my view the administrative track does more damage to most businesses. The bar is lower, there is no limitation period, and the sanction stops the export business itself.

The core provision is Article 53.² Paragraph 1 lets METI ban anyone who exported without an Article 48(1) license from exporting goods and providing technology for up to three years. Paragraph 2 covers other export and import violations with a one-year ceiling, extended to three years for violations of Japan's own countermeasures adopted by cabinet decision, such as the measures on North Korea. Article 25-2 sets up the same structure for technology: up to three years for unlicensed transfers under Article 25(1), and up to one year for violations such as the Group A inform requirement.

The officer restrictions are easy to miss. Under Article 53(3), when the violator is an individual, METI can bar that person from serving as the officer in charge of the same line of business at any company for the length of the ban. Article 53(4) lets METI bar a corporate violator's officers, anyone who was an officer in the 60 days before the sanction, and certain managers from starting the same business elsewhere, including by becoming the responsible officer at another company. Closing the company and reopening under a new name does not work. These rules came in with the 2017 amendment.¹⁴

Short of sanctions, there are two lighter responses. A METI warning names the company as a rule. A written explanation or report focused on root cause and prevention is, as a rule, not published.¹ Because criminal penalties, sanctions, and warnings are normally made public, customers and banks see them, and the business impact goes well beyond the legal penalty.

Japan's Center for Information on Security Trade Control (CISTEC) sums up the difference neatly.⁴ Criminal penalties apply to intentional violations; administrative sanctions apply to negligent ones too. Administrative sanctions have no limitation period, and they have been imposed in cases where criminal charges were time-barred or prosecutors declined to charge. The three-year import ban METI announced in March 2026 covered imports made between June 2019 and January 2020,¹⁵ more than six years before the sanction.

Corporate fines come through the dual liability provision in Article 72. When an officer or employee commits a violation in the course of business, the company is fined on top of whatever happens to the individual, at higher ceilings: up to ¥1 billion for the WMD tier, ¥700 million for other listed items, and ¥500 million for the Article 69-8 tier. That structure also dates from 2017. A fine is paid once. A three-year export ban shuts down the export business for three years, and that is why I take the administrative track more seriously.

METI's Published Sanctions and Warnings, 2021 to 2026

If you are looking for a list of FEFTA enforcement cases, METI's press releases are the place to start. The table below lists the sanctions and warnings published between 2021 and October 29, 2026 that I could confirm in METI releases, newest first, with the provision each one breached. METI's releases name the parties; I describe them by type here. The table records published enforcement facts and says nothing about how these businesses operate today.

Published	Party	What happened	Outcome	Provision breached
Mar 24, 2026	Individual	Imported 537,660 kg of North Korean-origin clams via China or South Korea in 35 shipments without approval, June 2019 to January 2020	Ban on importing any goods from anywhere, plus officer ban, for three years (Mar 31, 2026 to Mar 30, 2029)	Import approval (Art. 52); sanction under Art. 53(2) and (3)
Dec 16, 2025	Motorcycle retailer (company)	Exported motorcycles subject to Russia export restrictions to Russia without approval, 2022 to 2024	Warning (company named)	Export approval (Art. 48(3))
May 9, 2025	Trading company and its representative director	Exported 523 items, including motorcycles and personal watercraft, to Russia in 18 shipments between August 2022 and June 2023, declaring South Korea as the destination	One-year export ban and officer ban (May 16, 2025 to May 15, 2026; now expired)	Export approval (Art. 48(3)); sanction under Art. 53(2) and (3)
Oct 1, 2024	Individual	Concealed and imported three CITES-listed parrotlets from Thailand without approval, February 2023	Import ban on CITES-listed species and officer ban for five months	Import approval (Art. 52); sanction under Art. 53(2) and (3)
Jun 30, 2023	Machine tool exporter (company)	Exported controlled machine tools and other goods to China, Vietnam, and elsewhere without licenses, 2014 to 2022	Warning (company named)	Unlicensed export (Art. 48(1))
Jun 30, 2023	Importer (company)	Imported six CITES-listed animal skeleton and skull specimens from the U.S. without approval in February 2020 and April 2021	Warning (company named)	Import approval (Art. 52)
Apr 16, 2021	University faculty member (individual)	Brought paintings, leather shoes, beer, and other goods shipped from North Korea home in personal luggage without approval, August 2019	Warning	Import approval (Art. 52)

Sources are the individual METI press releases and METI's list of parties under administrative sanctions as of May 16, 2026.^{1516171819201021} That list shows only one active sanction, the first case in the table. I found no sanction or warning announced after March 24, 2026 in news or published materials as of October 29. METI's website could not be retrieved automatically, though, so I could not read its latest press release page directly. Read the table as what I could confirm.

Three patterns stand out. Most cases are approval violations, and Russia-related controls now reach ordinary goods such as motorcycles. Imports count too: North Korean goods are banned outright, and even items a university faculty member carried home in luggage drew a warning. And old transactions still get processed: the machine tool case covered exports from 2014 through 2022, and the clam case was sanctioned more than six years after the imports.

Named cases like these are the exception, though. In FY2024, METI imposed no sanctions and issued no warnings for security export control violations at all. For the background of individual cases and historical ones such as the Toshiba Machine COCOM affair, see Japan export control violation cases.

Some cases do go criminal. On July 10, 2024, Osaka prefectural police arrested the representative director of a trading company on suspicion of exporting goods covered by Japan's Russia sanctions without government approval, the first arrest in Japan over illegal exports to Russia since the invasion of Ukraine.¹¹

Being charged is not the same as being guilty, however. In 2020, three executives of the spray dryer maker Ohkawara Kakohki were arrested and indicted on suspicion of unlicensed exports. Prosecutors withdrew the indictment in July 2021, and in May 2025 the Tokyo High Court ruled that the investigation had been unlawful, a decision that is now final.²² A legitimate maker of civilian equipment was drawn into criminal proceedings over how a control-list term should be read, and was later vindicated. I cover the case in detail in the Ohkawara Kakohki case.

Where Violations Happen and How They Surface (METI's FY2024 Analysis)

METI's security export control inspection office publishes an analysis of the cases it closes each year. The latest, for FY2024, was released in December 2025 and covers dispositions decided between April 2024 and March 2025.⁶ METI gives percentages only, not case counts.

Outcomes: 69% of cases closed with a written report, 26% with a written explanation plus an oral caution, and 5% with a written explanation plus a formal written caution. There were no administrative sanctions and no warnings, and the document notes that no dispositions were made for intentional, malicious violations. On causes, 52% involved classification, led by "no classification performed, assumed not controlled" at 32%, followed by classification or legal interpretation errors at 15% and reliance on someone else's incorrect classification at 5%. Governance problems such as missing rules or structures accounted for 36%, transaction review errors such as misapplying license exemptions for 10%, and intent for 2%. In FY2023, classification issues were 70% and written reports 79%,²³ so the center of gravity has moved from making the wrong call to skipping the step entirely.

How violations surface has shifted too. In FY2024, 59% were found by customs post-clearance audits, which go back through records and transactions after goods have cleared, so paperwork that looked fine at the border can still be challenged later. Only 30% were found by the companies themselves. Of the companies involved, 71% had not filed an internal compliance program (CP) with METI, 61% had capital of ¥300 million or less, and 64% had 300 or fewer employees. This is mostly a story about companies too small to have a dedicated export control person. For more on these numbers, see METI's FY2024 violation data, and for six years of data side by side, where export control violations actually get caught.

Once a violation surfaces, METI runs a post-clearance review: the security export control inspection office handles list and catch-all cases, and the trade control division handles approval and import cases. The exporter submits a case questionnaire and classification records and must identify root causes and put prevention measures in place. METI then weighs the cause, the actual end use, and how cooperative the company was in deciding between a report or written explanation, a warning, or a sanction.¹ If an intentional violation is pursued as a criminal case, police and prosecutors take it from there.

If you find a violation, the right first move is to pin down the facts and report to METI. METI's guidance says voluntary disclosure may be taken into account in the outcome.¹ For businesses that export controlled items, the ministerial ordinance on exporter compliance standards goes further: when a company has violated, or may have violated, the relevant laws, it must report promptly to the Minister of Economy, Trade and Industry and take the measures needed to prevent recurrence.²⁴ The same facts read very differently when you bring them forward yourself than when customs finds them first.

Then and Now: How the Penalties Got Heavier

Today's penalties are the result of several rounds of tightening. The 2016 row reflects the pre-2017 text still available on e-Gov; later rows reflect the text after each amendment.²¹⁴²⁵⁵

Point in time	General listed items	WMD-related	5-year tier	Corporate fines	Administrative sanctions
Before the 2017 amendment (2016)	Up to 7 years, ¥7 million (Art. 69-6(1))	Up to 10 years, ¥10 million (Art. 69-6(2))	Up to 5 years, ¥5 million (Art. 69-7)	Same as individuals	Up to 3 years for unlicensed exports; 1 year otherwise
From Oct 1, 2017 (amendment promulgated May 2017)	Fine raised to ¥20 million	Fine raised to ¥30 million	Fine raised to ¥10 million	Separate corporate caps of ¥700 million, ¥1 billion, and ¥500 million	Up to 3 years for violating Japan's own measures; officer bans introduced
From Jun 1, 2025	"Penal servitude" becomes "imprisonment" (kokinkei)	Same	Same	Unchanged	Unchanged
From Jun 5, 2026 (Act No. 30 of 2026, partly in force)	Renumbered to Art. 69-7(1)	Renumbered to Art. 69-7(2)	Renumbered to Art. 69-8	Art. 72 cross-references updated	Unchanged
Jan 4, 2027 (scheduled)	Unchanged	Unchanged	Unchanged	Unchanged	New Article 70 offenses tied to inbound investment screening
Oct 16, 2026 (order in force; no change to the penalty articles)	Unchanged	Unchanged	Goods requiring approval for Russia expanded	Unchanged	Unchanged

METI framed the 2017 amendment as strengthening deterrence against the outflow of sensitive technology and goods. It raised the maximum fine from ¥10 million to ¥30 million and created separate corporate fines of up to ¥1 billion.¹⁴ On June 1, 2025, Japan's revised Penal Code merged imprisonment with and without labor into a single custodial sentence, and FEFTA's text changed accordingly;²⁵ an older reference to "10 years of penal servitude" describes the same severity as today's "10 years of imprisonment." The part of the 2026 amendment scheduled for January 4, 2027 concerns inbound investment screening and leaves the export penalties alone.

This article has been through the same kind of correction. The first version in January 2026 described the criminal penalty as a flat "up to 10 years and ¥1 billion." The July update split it into three tiers but put all catch-all violations in the 5-year tier, which was wrong. This update moves catch-all exports outside Group A into the 7-year tier, adds the Article 70 and 71 tiers and limitation periods, and replaces METI's FY2023 analysis with FY2024. Since 2022, Russia-related controls have reached everyday goods such as motorcycles, and most published enforcement now involves approval violations. The idea that only exotic military-grade items need attention no longer holds.

When "It Doesn't Apply to Us" Breaks Down, and What to Do About It

FEFTA obligations fall on whoever exports the goods or provides the technology. In an indirect export, where a trading company ships a manufacturer's product, the trading company is the legal exporter and the one held responsible, a point METI's guidance makes explicitly.¹ An IT company sharing controlled technology with an overseas office through the cloud may be providing technology, and a university teaching controlled technology to a foreign student may be making a deemed export. A university faculty member even appears in the enforcement table above, although that case involved imports carried in luggage. Research settings are not exempt.

There is a safe harbor worth knowing about. For deemed exports, METI's guidance says that if you check whether a recipient falls into a specified category by following METI's guideline, you are treated as having exercised due care, so even if the person later turns out to be covered, failing to get a license is regarded as non-negligent and does not lead to penalties or administrative action.¹ The flip side is that skipping the documented check forfeits that protection. A written procedure that is actually followed is itself a legal defense. For details, see deemed exports and the specified categories.

"We only sell commercial products" is not a shelter either. As covered above, unlisted general-purpose items can need a license under the catch-all controls, and for destinations outside Group A the penalty tier is the same as for listed items.

Prevention still comes down to four habits: classify every export, screen counterparties and end uses before shipment, keep the basis for each decision on file, and maintain the internal rules and training that make this happen. Our guides on Japan's export classification steps and building an export control framework from scratch cover the mechanics. Given that the most common FY2024 violation was skipping classification altogether, I would fix the gaps where classification gets skipped before trying to make each classification more accurate.

That is the kind of workflow TRAFEED, TIMEWELL's export control AI agent, is built to support. It drafts the Japan export classification, screens counterparties against restricted party lists including METI's End User List and the U.S. Entity List, supports end-user checks in the same flow, and keeps the evidence for each decision on file. Being on any of these lists is a regulatory designation, not a judgment about the company or organization. The classification method has a granted Japan patent (No. 7862062). Your export control officer makes the final call; the AI does not. This article is general information about Japanese law, not legal advice.

Frequently Asked Questions

What is the maximum penalty for a FEFTA export violation?

The heaviest tier covers unlicensed exports or transfers of goods and technology designated as particularly likely to be used for nuclear, chemical, or biological weapons or missiles: up to 10 years of imprisonment and/or ¥30 million for individuals, and up to ¥1 billion for corporations (Articles 69-7(2) and 72). Other listed items carry up to 7 years and ¥20 million, or ¥700 million for corporations. If five times the value of the goods exceeds the cap, the ceiling becomes five times the value.

Are catch-all violations punished less severely than list control violations?

Not for destinations outside Group A. Once a catch-all requirement is triggered for a row 16 item, the export needs the same Article 48(1) license as a listed item, and exporting without it falls under Article 69-7(1), up to 7 years. Exporting to Group A without a license after an inform notice (Article 48(2)) falls under Article 69-8, up to 5 years.

Is there a statute of limitations?

Criminal charges become time-barred after 7 years for the 10-year tier, 5 years for the 7-year and 5-year tiers, and 3 years for the 3-year tier, and corporate fines follow the same periods. Administrative sanctions have no limitation period; in 2026 METI imposed a three-year import ban for imports made in 2019 and 2020.

Can an honest mistake lead to penalties?

Criminal penalties generally require intent, but administrative sanctions can be imposed for negligence. Most cases are minor in practice: in FY2024, 69% closed with a written report. Voluntary disclosure may be taken into account.

Where can I find FEFTA violation cases?

METI's security export control review page carries annual violation analyses, and its trade control review page lists parties under sanctions along with the related press releases. The table in this article covers the cases published from 2021 to 2026 and the provision each one breached.

Key Takeaways

• FEFTA's criminal penalties for unlicensed exports run in tiers: 10 years and ¥1 billion for WMD-related items, 7 years and ¥700 million for other listed items and for catch-all exports outside Group A, and 5 years and ¥500 million for Group A inform violations and missing approvals. Fines can rise to five times the value of the goods
• The June 5, 2026 amendment renumbered the penalty articles; today's Article 69-7 is the old 69-6
• Separately, METI can impose export bans of up to three years and officer bans, even for negligence and with no limitation period
• Published enforcement is mostly about approvals (Russia, North Korea, CITES), and in FY2024 there were no sanctions or warnings for security export control violations
• The main cause of violations is skipped classification, and 59% are found by customs post-clearance audits

A penalty table cannot tell you which row your own shipments belong in. Only your classification and screening records can. Pick a few recent export files and trace who checked the control list, the destination's Group A status, and any inform notice, and on what evidence. Wherever you cannot trace it, that is where to start. If you want a second pair of eyes on how your program is set up, talk to us about TRAFEED.

References

Related Articles

• Japan export control violation cases
• List controls vs catch-all controls in Japan
• METI's FY2024 violation data
• Where export control violations actually get caught
• The Ohkawara Kakohki case
• Japan's export classification steps
• Building an export control framework from scratch

Footnotes

1. METI, Security Export Control Guidance (Introductory), 3rd edition, March 2026: penalties for violations, consideration of voluntary disclosure, post-clearance review, liability in indirect exports, the specified-category guideline and non-negligence, and the exporter compliance standards with Article 71. https://www.meti.go.jp/policy/anpo/guidance/guidance.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

2. e-Gov, Foreign Exchange and Foreign Trade Act (Act No. 228 of 1949), version in force since August 12, 2026 (current as of October 29, 2026; includes the amendment by Act No. 64 of 2026): Articles 25, 25-2, 48, 52, 53, 55-12, 69-7, 69-8, 70, 71, and 72. Pre-2017 comparison uses the version in force from April 1, 2016 (checked October 29, 2026). https://laws.e-gov.go.jp/law/324AC0000000228 ↩ ↩² ↩³ ↩⁴

3. e-Gov, Code of Criminal Procedure, Article 250(2) (checked October 4, 2026). https://laws.e-gov.go.jp/law/323AC0000000131 ↩

4. CISTEC, "If a violation is found through self-management." https://www.cistec.or.jp/service/jisyukanri_ihan.html ↩ ↩²

5. e-Gov amendment history for FEFTA. Act No. 30 of 2026 was promulgated on June 5, 2026; the provisions in force that day added Article 69-5 (information sharing with foreign enforcement authorities), and the remainder is scheduled for January 4, 2027 (checked October 4, 2026). Bill overview from Japan's Ministry of Finance: https://www.mof.go.jp/about_mof/bills/221diet/kb20260317g.html ↩ ↩²

6. METI, Analysis of FEFTA Violation Cases (Security Export Control), FY2024, December 2025. https://www.meti.go.jp/policy/anpo/gaitameho_document/ihanjireigaitamehou6.pdf ↩ ↩²

7. e-Gov, Foreign Exchange Order, Article 17(1), (2), and (5) (checked October 4, 2026). https://laws.e-gov.go.jp/law/355CO0000000260 ↩ ↩²

8. e-Gov, Export Trade Control Order, Article 1(1) and (3), Article 4(2), and row 16 of Appended Table 1 (version in force since June 5, 2026; checked October 4, 2026). https://laws.e-gov.go.jp/law/324CO0000000378 ↩

9. METI, Catch-all controls (supplementary export controls). The Group A inform requirement applies only where there is a risk of diversion to countries of concern. https://www.meti.go.jp/policy/anpo/catchall.html ↩

10. METI press release on a warning to a FEFTA violator, April 16, 2021, including the note that all imports originating in or shipped from North Korea have been banned since October 14, 2006. https://www.meti.go.jp/press/2021/04/20210416006/20210416006.html ↩ ↩²

11. Baker McKenzie, "Sanctions against Russia: First case of arrests for alleged violations," July 16, 2024. https://www.bakermckenzie.co.jp/wp/wp-content/uploads/20240716-ClientAlert-ITC.pdf ↩ ↩²

12. Ministry of Finance, Customs and Tariff Bureau, Notice No. 1185 (October 9, 2026) on customs handling of the ban on goods supporting Russia's industrial base and on exports to specified entities in third countries (Cabinet Order No. 325 of 2026, amending the Export Trade Control Order, in force October 16; in Japanese). https://www.customs.go.jp/kaisei/zeikantsutatsu/kobetsu/TU-R08z1185.pdf ; Ministry of Finance, "Measures under the Foreign Exchange and Foreign Trade Act concerning the situation in Ukraine" (October 2, 2026; in Japanese). https://www.mof.go.jp/policy/international_policy/gaitame_kawase/gaitame/economic_sanctions/20261001212931.html ↩

13. METI Trade Control Division, Trends and Examples in Post-Clearance Review Cases, May 2026. https://www.meti.go.jp/policy/external_economy/trade_control/01_seido/02_jigo/download/202605jigoshinsajiannokeikoujirei.pdf ↩

14. METI, press release on the cabinet decision on the FEFTA amendment bill, March 3, 2017. https://www.meti.go.jp/policy/anpo/law_document/20170524_1.pdf ↩ ↩² ↩³

15. METI press release on an administrative disposition (import ban), March 24, 2026. https://www.meti.go.jp/press/2025/03/20260324002/20260324002.html ↩ ↩²

16. METI press release on a warning to a company, December 16, 2025. https://www.meti.go.jp/press/2025/12/20251216001/20251216001.html ↩

17. METI press release on administrative dispositions (export ban), May 9, 2025. https://www.meti.go.jp/press/2025/05/20250509001/20250509001.html ↩

18. METI press release on an administrative disposition (import ban), October 1, 2024. https://www.meti.go.jp/press/2024/10/20241001001/20241001001.html ↩

19. METI press release on a warning to a company (unlicensed exports of machine tools), June 30, 2023. https://www.meti.go.jp/press/2023/06/20230630006/20230630006.html ↩

20. METI press release on a warning to a company (unapproved imports of CITES-listed specimens), June 30, 2023. https://www.meti.go.jp/press/2023/06/20230630005/20230630005.html ↩

21. METI, List of parties under administrative sanctions (export/import bans), as of May 16, 2026, on the post-clearance review page. https://www.meti.go.jp/policy/external_economy/trade_control/01_seido/02_jigo/jigoshinsa.html ↩

22. CISTEC, commentary on the legal interpretation in the final Tokyo High Court judgment in the Ohkawara Kakohki state compensation case, August 8, 2025. https://www.cistec.or.jp/service/houtaikei_saikochiku_data/20250808.pdf ↩

23. METI, Analysis of FEFTA Violation Cases (Security Export Control), FY2023, December 2024. https://www.meti.go.jp/policy/anpo/gaitameho_document/ihanjireigaitamehou5.pdf ↩

24. e-Gov, Ministerial Ordinance Establishing Exporter Compliance Standards (METI Ordinance No. 60 of 2009), Article 1, item 2, sub-item nu (checked October 4, 2026). https://laws.e-gov.go.jp/law/421M60000400060 ↩

25. House of Councillors Legislative Bureau, on merging penal servitude and imprisonment into a single custodial sentence (Act No. 67 of 2022, effective June 1, 2025). https://houseikyoku.sangiin.go.jp/column/column119.htm ↩ ↩²