Overseas Firms & Cross-Border Solicitation Watch

Being Based Overseas Does Not Exempt a Firm

The Financial Instruments and Exchange Act generally requires registration for any activity that constitutes financial instruments business (solicitation, sales, etc.) directed at investors located in Japan, regardless of where the firm is based. Firms sometimes explain that they hold "an overseas financial license" or are "a legally operating firm overseas," but such explanations do not justify conducting unregistered business in Japan.

Patterns Commonly Seen in Cross-Border Solicitation

Based on materials published by the FSA and Local Finance Bureaus, and other generally known information, the following are patterns commonly seen among unregistered firms based overseas (this describes general tendencies and is not a determination about any specific firm).

• Unable to provide a Japanese registration number for financial instruments business, or gives only vague answers when asked for one
• What appears to be the same operation continues soliciting under a new brand or service name after a short period
• Contact is limited to overseas customer support, making it difficult to confirm a Japanese-language contact point or physical address
• Requests additional transfers to individually held Japanese bank accounts, citing taxes or withdrawal fees
• Solicitation begins through social media ads or messaging apps and avoids in-person or phone-based communication

About Individual Cases

Numerous warnings against unregistered overseas firms are published in lists maintained by the Kanto Local Finance Bureau and the Financial Services Agency. This site adds individual cases to Unregistered Firms as we complete review sufficient to accurately cite each firm's name and warning date. The absence of a specific firm from this page reflects the pace of our review process, not an absence of targets. For the most current information, please check the public authority sources linked above directly.