title: Japan — Conduct, Safeguarding & Promotions | World Payments Monitor canonical: https://payments.gi/jurisdictions/japan/w1b/ publisher: Asymmetric Intelligence ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-06-27 Safeguarding for non-bank FTSPs is achieved primarily through a Performance Security Deposit (cash deposit with the Legal Affairs Bureau), with bank performance bonds and trust arrangements as alternatives; crypto/EPI custody requires segregation. The FSA supervises conduct via its Comprehensive Supervision Guidelines and the Guideline for Supervision of Funds Transfer Service Providers, which embed AML/CFT and user-protection expectations. Stablecoin/crypto intermediaries face explicit disclosure, explanation and prohibited-conduct rules under the 2025 reforms. Horizon · 2026-06 (± a quarter) FSA crypto/EPI intermediary conduct rules take effect_Adopted, not yet in force · Tier 2 source_ Standing sub-brief · as of 16 August 2026 188 words · last cycle 2026-08-16 #### Conduct, Safeguarding & Financial Promotions Trust-type electronic payment instrument issuers may now hold up to 50% of backing assets in short-term Japanese government bonds of three months or less, or in early-cancellable term deposits, relaxing the prior requirement that reserves sit wholly in demand deposits. Separately, fund-transfer operators gain an optional bank- or trust-backed direct-reimbursement mechanism that sits alongside the existing kyotaku statutory deposit route, giving non-bank payment institutions a second safeguarding pathway for user funds held on failure. Both changes apply specifically to the non-bank payment-institution and EPI-issuer population rather than to deposit-taking banks, which continue to safeguard customer funds under existing banking-sector prudential rules; the reforms therefore widen, rather than replace, the menu of safeguarding options available to non-bank operators without altering the bank-side baseline. This is the live safeguarding-and-conduct item for Japan this cycle, distinct from the market-access and licensing changes tracked separately. #### Outlook How trust-type issuers and fund-transfer operators actually elect between the relaxed reserve-composition option, the new direct-reimbursement mechanism and the existing kyotaku route will be the practical signal to watch as institutions adjust their safeguarding arrangements following the 13 June 2026 commencement. No new data since the standing brief. 1 periodic run re-emitted it unchanged. **Sources and findings (4)** 1. T3 [https://www.mofo.com/resources/insights/200715-reforms-japanese-regulations.html](https://www.mofo.com/resources/insights/200715-reforms-japanese-regulations.html) retrieved 2026-06-27 2. T1 [https://www.fsa.go.jp/common/law/guide/kaisya/e014.pdf](https://www.fsa.go.jp/common/law/guide/kaisya/e014.pdf) retrieved 2026-06-27 3. T2 [https://www.mexc.com/news/1109792](https://www.mexc.com/news/1109792) retrieved 2026-06-27 4. T2 [https://practiceguides.chambers.com/practice-guides/financial-services-regulation-2025/japan/trends-and-developments](https://practiceguides.chambers.com/practice-guides/financial-services-regulation-2025/japan/trends-and-developments) retrieved 2026-06-27