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pc nid 92236 Apr 28, 2026 kgurnani@vixio.com Japan Financial Services Agency horizon scanning
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Japan's Financial Services Agency Issues Request on Cryptocurrency-Based Real Estate Transactions

On April 28, 2026, the Financial Services Agency (FSA) issued a request regarding cryptocurrency-based real estate transactions. The FSA coordinated this request with the Ministry of Land, Infrastructure, Transport and Tourism, the National Police Agency, and the Ministry of Finance. The request was directed at industry associations and relevant stakeholders concerning the use of cryptocurrency in real estate transactions. The FSA's action reflects growing regulatory attention to the intersection of digital assets and property markets in Japan. This coordinated multi-agency approach indicates heightened concern about potential risks associated with cryptocurrency use in real estate dealings, including anti-money laundering and counter-terrorism financing considerations, as well as consumer protection matters. The request represents a proactive regulatory stance on emerging financial practices that combine cryptocurrency with traditional real estate markets. By engaging industry bodies, the FSA aims to establish expectations and standards for handling such transactions before formal regulatory frameworks are implemented. Stakeholders in Japan's real estate and cryptocurrency sectors should monitor further guidance from the FSA and its partner agencies regarding compliance expectations for cryptocurrency-based property transactions. The FSA's Comprehensive Policy Bureau, Risk Analysis and Coordination Division, Cryptocurrency, Blockchain and Innovation Division, remains the responsible office for inquiries related to this matter. REFERENCE: Financial Services Agency of Japan. "Request Regarding Real Estate Transactions Using Cryptocurrency" (April 28, 2026). Available at: https://www.fsa.go.jp/

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Japan's Financial Services Agency Issues Request on Cryptocurrency-Based Real Estate Transactions

On April 28, 2026, Japan's Financial Services Agency (FSA), in coordination with other government ministries, issued a notice warning the real estate industry about the risks of using crypto assets in real estate transactions, particularly for money laundering and unregistered crypto exchange activity. The authorities highlighted a few risks related to such transactions: Real estate involves high-value transactions and is often used for asset preservation and investment, making it attractive for domestic and international criminal organisations seeking to launder criminal proceeds. Crypto assets increase this risk because they can be transferred instantly across borders and may be used to obscure the source of funds. If a real estate broker or seller receives crypto assets as payment for property and then converts those crypto assets into legal tender (fiat), this may constitute a “crypto asset exchange business” under Japan’s Payment Services Act. Under the Act on Prevention of Transfer of Criminal Proceeds, real estate brokers must: carefully verify transaction timing and customer circumstances pay close attention to expensive transactions that do not match the customer’s profile or attributes report suspicious transactions to the relevant authorities notify police where criminal activity is suspected carefully verify transaction timing and customer circumstances pay close attention to expensive transactions that do not match the customer’s profile or attributes report suspicious transactions to the relevant authorities notify police where criminal activity is suspected If a person receives crypto assets from overseas exceeding the equivalent of JPY 30 million (~$188,000) and acquired Japanese real estate, a “Report on the Acquisition of Real Estate or Rights Related Thereto Located in Japan” may be required, under the Foreign Exchange and Foreign Trade Act.