Centralized exchange in Japan
Order-book exchange that takes custody of user assets and matches trades between users.
CEX 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/AML procedures required under PSA and FIEA, aligned with FATF recommendations (jp.licensing.anti-money-laundering-aml-counter-terrorist-financing)
- Transaction monitoring and suspicious activity reporting (SAR) to FSA (jp.licensing.anti-money-laundering-aml-counter-terrorist-financing)
- Travel Rule applies at JPY 0 threshold — no minimum; full originator/beneficiary information required on all withdrawals and transfers (jp.travel-rule.status, jp.travel-rule.fsa-announcement-and-implementation-httpswwwsygnaioblogjapan-implements-fatfs-crypto-travel-rule1)
- Customer due diligence (CDD) / KYC on all customers (jp.licensing.anti-money-laundering-aml-counter-terrorist-financing)
Key Restrictions
- Must obtain CAESP registration from FSA (6–18 month application timeline) (jp.licensing.vasp, jp.licensing.exchange)
- Mandatory membership in JVCEA (self-regulatory organization) (jp.licensing.vasp, jp.licensing.regulator-jvcea)
- Token listings must be pre-screened by JVCEA (green/white list standards) (jp.licensing.regulator-jvcea, jp.licensing.vasp)
- Margin trading capped at 2x leverage (jp.licensing.exchange)
- Stablecoin intermediation requires separate fund transfer service provider registration (jp.licensing.exchange)
- JPY 10M (~$70K USD) minimum capital; must maintain positive net assets (jp.licensing.vasp)
- Customer crypto-assets must be segregated in trust accounts or equivalent; cold storage recommended for majority (jp.licensing.vasp, jp.licensing.custody, jp.licensing.segregation-of-customer-assets-vceps)
- Multi-signature wallets, penetration testing, and internal audits required (jp.licensing.custody, jp.licensing.robust-security-measures-strict-requirements)
Key Risks
- Long licensing timeline (6–18 months) creates market-entry delay (jp.licensing.vasp)
- High regulatory scrutiny from FSA with power to revoke licenses and issue administrative orders (jp.licensing.supervision-and-enforcement-the-fsa)
- JVCEA green/white list process restricts which tokens can be listed, limiting product flexibility (jp.licensing.regulator-jvcea)
- Stablecoin Law (June 2023) restricts issuance to banks/trusts — exchanges can only intermediate via separate fund transfer service registration (jp.licensing.legislation-stablecoin-law-effective-june-2023, jp.licensing.exchange)
- Travel Rule at JPY 0 threshold imposes significant operational burden for all withdrawal flows (jp.travel-rule.status)
- Enforcement and tax scrutiny from both FSA and NTA (jp.enforcement.regulator-national-tax-agency-nta)
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
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.
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.
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.
The 2019 FIEA and PSA amendment (in force May 2020) brought security tokens and crypto-asset derivatives under the FIEA; Law No. 64 of 2026, promulgated 23 Jul 2026, moves crypto-asset trading regulation from the PSA to the FIEA, but its crypto provisions take effect on a date set by cabinet order within one year of promulgation and are not yet in force.
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.
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)).
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.
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.
The Payment Services Act lets the regulator demand reports and inspect crypto-asset exchange service providers (Art. 63-15), issue business improvement orders (Art. 63-16), and revoke registration or suspend business for up to six months (Art. 63-17); e.g. the Kanto Local Finance Bureau ordered DMM Bitcoin on 26 Sep 2024 and CoinBest on 14 Jun 2024.
Payment Services Act Art. 2(14) defines crypto-assets as electronically recorded property values usable for payment to unspecified persons and tradeable with unspecified persons, or exchangeable for such values, transferable electronically; fiat, currency-denominated assets, electronic payment instruments and FIEA electronically recorded transferable rights are excluded.
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.
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).
Robust Security Measures: Strict requirements for cybersecurity, including multi-signature wallets, penetration testing, and internal audits.
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).
Japan's crypto-asset travel rule, in force since 1 June 2023, is APTCP Article 10-5: a crypto-asset exchange service provider transferring crypto-assets at a customer's request to another provider must notify originator and beneficiary identification information; the article sets no monetary threshold, and the duty applies only to providers in jurisdictions with an equivalent rule — 58 jurisdictions, with Anguilla, Oman, Cuba, Dominica and Botswana being added in 2026.
FSA announcement and implementation: https://www.sygna.io/blog/japan-implements-fatfs-crypto-travel-rule/; https://www.fsa.go.jp/en/news/2025/20250625/01.pdf
Regulator: Financial Services Agency (FSA).
Regulator: National Tax Agency (NTA).
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a centralized exchange can operate in Japan only after obtaining CAESP registration from the FSA (~6–18 months), joining JVCEA as a mandatory SRO member, segregating customer assets, complying with the Travel Rule at JPY 0 threshold, and adhering to strict capital, security, and token-listing requirements.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?