Japan’s 4 prefectural government offices jointly request: Crypto-asset real estate transactions must strictly implement KYC and anti–money laundering measures

According to the official announcement released by Japan’s Financial Services Agency (FSA) on April 28 (full PDF), the FSA’s Comprehensive Policy Bureau Risk Analysis and Summary Division, the Real Estate Industry Division of the Ministry of Land, Infrastructure, Transport and Tourism’s Real Estate Construction and Economics Bureau, the Organization Crime Countermeasures Department Organization Crime Countermeasures Division 1 of the National Police Agency, the Ministry of Finance’s International Bureau Investigation Division, and other four ministries and agencies jointly issued a request titled “暗号資産を用いた不動産取引について（要請）” (“Request regarding real estate transactions using crypto assets”) to seven industry groups.

4 agencies jointly issued a request to 6 real estate associations and JVCEA

The recipients of this request are 7 industry groups:

公益社團法人 全國宅地建物取引業協會連合會

公益社團法人 全日本不動產協會

一般社團法人 不動產協會

一般社團法人 不動產流通經營協會

一般社團法人 全國住宅產業協會

公益財團法人 不動產流通推進中心

一般社團法人 日本暗號資產等取引業協會（JVCEA）

The background explanation states: real estate property values handled by real estate transaction businesses are high and can be exchanged for large amounts of cash, creating risks of being used for crimes such as money laundering; in recent years, purchases of real estate for asset preservation and investment purposes have increased, and domestic and overseas criminal organizations may also use real estate transactions to convert proceeds from crime into different forms. The document specifically points out that “crypto assets are considered to have a high risk of being used for money laundering as a settlement method for real estate transactions, due to their characteristic of being transferred across borders instantaneously.”

Specific requirements for real estate businesses: strictly comply with the Funds Settlement Act and the Act on Prevention of Transfer of Criminal Proceeds

There are two specific requirements for real estate businesses (real estate transaction businesses):

1. Acts involving conversion between crypto assets and legally designated currencies may constitute business in crypto asset exchange. Be reminded that “converting crypto assets into legally designated currencies, or acting as an intermediary for such conversion” may constitute crypto asset exchange business under the Funds Settlement Act. Engaging in such activities without registration may violate the Funds Settlement Act. If you identify circumstances that appear to involve unregistered parties conducting crypto asset exchange business, you should provide information to the police authorities; when real estate businesses, as sellers, receive crypto assets as the sale proceeds and then convert them into legally designated currencies, etc., they also must not use unregistered crypto asset exchange businesses.

2. When conducting transactions, strictly confirm under the Act on Prevention of Transfer of Criminal Proceeds (Act No. 22 of 2007). When conducting crypto asset real estate transactions, strict KYC is required; submit “suspicious transaction reports” to the competent administrative authority, and when there are grounds for suspicion related to an incident, report to the police authorities.

Requirements for crypto asset exchange businesses: watch for transactions where the customer profile does not match high-value transactions

Examples of specific situations involving crypto asset exchange businesses:

When there are suspicious transaction circumstances such as “the customer receives real estate sale proceeds in the form of crypto assets and conducts high-value transactions that do not match the customer’s attributes,” etc., you must conduct transaction confirmation under the requirement of strict procedures under the Act on Prevention of Transfer of Criminal Proceeds, and submit suspicious transaction reports to the competent administrative authority and report incident-related suspicions to the police authorities.

Reaffirmation of the Foreign Exchange Act: transactions involving cross-border crypto assets of 30 million yen or more and acquisition of real estate by non-residents require reporting

At the end, the document particularly reaffirms the two reporting obligations under the Foreign Exchange and Foreign Trade Act (Act No. 228 of 1949, i.e., the “Foreign Exchange Act”):

• Those who receive crypto assets, etc., equivalent to 30 million yen or more from overseas must submit a “Report on Payments or Receipt of Payments.”
• When a non-resident acquires real estate in Japan, etc., a “Report on the Acquisition of Real Estate in Japan or Rights Related Thereto” must be submitted. Here, it is specially noted that Japanese real estate acquired after April 1, Reiwa 8 (2026-04-01) is subject to reporting regardless of the purpose of acquisition.

This request is at the level of “administrative guidance” (request), not a new law or amendment. However, with four ministries and agencies jointly signing and sending it out simultaneously to both the real estate and crypto-asset industries, it shows that Japan’s recognition of AML risks in “real estate transactions using crypto assets as settlement instruments” has become concrete. Future developments in enforcement and industry compliance are worth watching.

This article, the joint request by Japan’s four ministries and agencies: the earliest mention that “real estate transactions using crypto assets require strict KYC and anti-money laundering” appeared on Chain News ABMedia.