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Crypto ATM / kiosk operator in Japan

Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.

Conditional AI-Generated · Unreviewed

Crypto ATM is conditionally permitted in Japan with a local entity, subject to AML obligations and high licensing burden.

Verdict Details

Permitted
conditional
Local entity required
Yes
Licensing burden
High
Last updated
2026-07-13

AML Obligations

  • Comprehensive KYC (customer identification, verification) required under PSA and FATF-aligned AML/CFT rules
  • Transaction monitoring for all cash-in/cash-out crypto transactions
  • Suspicious Activity Reporting (SAR) obligations to FSA
  • Travel Rule compliance (originator/beneficiary information sharing) for transactions
  • Cash transaction reporting — the PSA/FSA framework applies to all CAESP-registered entities operating crypto-asset exchange services, including cash-to-crypto at kiosks

Key Restrictions

  • Must register as a Crypto-Asset Exchange Service Provider (CAESP) with the FSA — no kiosk-specific license exists; kiosk operators fall under the general VASP/CAESP regime
  • Minimum capital of JPY 10M (~$70K USD) required
  • Must maintain positive net assets at all times
  • Must join JVCEA (mandatory self-regulatory organization) and comply with its operational rules
  • Customer crypto-assets must be segregated (trust account or equivalent); 100% cold storage recommended
  • Margin trading (if applicable) capped at 2x leverage — but kiosks typically do not offer margin
  • Stablecoin intermediation at kiosks requires separate fund transfer service provider registration
  • 6–18 month application timeline for FSA registration

Key Risks

  • High-cash AML risk profile attracts enhanced scrutiny from FSA given enforcement posture
  • Cash-to-crypto kiosks present higher typology risk for money laundering and terrorist financing, likely triggering on-site inspections
  • No dedicated kiosk-specific license pathway — regulatory ambiguity around how cash transaction reporting thresholds apply to crypto kiosks specifically
  • Potential NTA scrutiny on cash transaction reporting for amounts over JPY 2M per transaction (general cash reporting rules may apply)
  • Enforcement precedent: FSA can issue administrative orders, impose penalties, and revoke licenses for non-compliance

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 90% confidence

The FSA (with Local Finance Bureaus) registers and supervises crypto-asset exchange service providers (PSA Art. 63-2) and EPI exchange service providers (Art. 62-3), and drafted Law No. 64 of 2026, which moves crypto-asset trading to the FIEA; that law’s crypto provisions are not yet in force.

licensing 88% confidence

JVCEA is the certified association under PSA Art. 87, but membership is not mandatory: an applicant may instead adopt equivalent internal rules (PSA Art. 63-5(1)(vi)). New tokens require prior notification to the JVCEA, which may object (Rule on Handling of Crypto-Assets Art. 5); it also audits and sanctions members.

licensing 90% confidence

The Payment Services Act (Act No. 59 of 2009) crypto regime of registration, customer verification and asset segregation took effect in April 2017; a 2019 amendment in force May 2020 made changes to handled crypto-assets subject to prior notice, added advertising rules and required user crypto to be held in cold wallets in principle.

licensing 90% confidence

Crypto-asset exchange service providers register under PSA Art. 63-2 with capital of at least ¥10 million and non-negative net assets (CAESP Ordinance Art. 9). Cold storage is mandatory except a 5% hot-wallet cap (Art. 27(2)). JVCEA membership is optional if equivalent internal rules are adopted (PSA Art. 63-5(1)(vi)); new tokens need prior notice to the JVCEA.

licensing 90% confidence

Custody of crypto-assets for others (PSA Art. 2(15)(iv)) is crypto-asset exchange business requiring Art. 63-2 registration. User money must be entrusted to a trust company (Art. 63-11(1)); user crypto must be segregated and held by the cold method, with hot-wallet holdings capped at 5% (CAESP Ordinance Art. 27), and segregation is audited by a CPA or audit firm (Art. 63-11(3)).

licensing 92% confidence

Crypto-asset exchange business requires Payment Services Act Art. 63-2 registration; individual margin must be at least 50% of the position, i.e. 2x maximum leverage (CAESP Ordinance Art. 25(5)(i)). Dealing in or intermediating stablecoins requires registration as an electronic payment instrument exchange service provider (PSA Arts. 2(10), 62-3); the FSA listed 2 as of 27 Aug 2026.

licensing 92% confidence

All crypto-asset exchange service providers (暗号資産交換業者, CAESPs) must be registered with the Prime Minister under Payment Services Act Art. 63-2; the PSA regime is a registration, not a licence, and the FSA register listed 27 registered providers as of 1 Sep 2026.

licensing 93% confidence

Crypto-asset exchange business under Payment Services Act Art. 2(15) covers buying, selling or exchanging crypto-assets, intermediating, brokering or acting as agent for these, managing user money in connection with them, and custody of crypto-assets for others; it requires registration with the Prime Minister (Art. 63-2), not a licence.

Evidence fact jp.licensing.core-requirements-for-licensed-exchanges not found (may have been renamed).

licensing 90% confidence

Crypto-asset exchange service providers must hold users' crypto-assets separately from their own so each user's holding is immediately identifiable (CAESP Ordinance Art. 27(1)), keep them in cold storage except a hot-wallet portion capped at 5%, and hold their own crypto of the same kind and amount against hot-wallet user crypto (PSA Art. 63-11-2).

licensing 20% confidence

Robust Security Measures: Strict requirements for cybersecurity, including multi-signature wallets, penetration testing, and internal audits.

licensing 92% confidence

Crypto-asset exchange service providers are specified business operators under the Act on Prevention of Transfer of Criminal Proceeds (Act No. 22 of 2007, Art. 2(2)(xxxii)); they must conduct customer verification (Art. 4), file suspicious transaction reports (Art. 8), and notify originator and beneficiary information to the receiving provider on customer crypto transfers to other providers (Art. 10-5).

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
medium

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

Conditional — Crypto ATM/kiosk operators in Japan must register as CAESP (Crypto-Asset Exchange Service Provider) with the FSA, join JVCEA, meet JPY 10M minimum capital and asset segregation requirements, and comply with comprehensive AML/KYC obligations, but there is no dedicated kiosk-specific license and cash transaction reporting thresholds are not explicitly defined for kiosks under the current framework.

Questions this verdict aims to answer

  • What money-transmitter / kiosk-specific license is required?
  • What cash-transaction reporting thresholds apply?
  • What enhanced-KYC obligations attach to cash-in / cash-out?