With companies such as TransferWise entering the Japanese market in late 2016 and overseas payment apps experiencing a boom worldwide, the potential of the Japanese funds transfer industry is drawing attention both at home and from overseas.
If you are considering engaging in Japan’s funds transfer industry, the first thing you will need to do is register as a Funds Transfer Service Operator.
The Registration Process
The steps to registering as a Funds Transfer Service Operator are as follows:
Submit an outline of your application to the Financial Services Agency (FSA)
- Interview/feedback session with the FSA
- Submit application documents. These must show compliance with more than 20 official regulations (e.g. anti money laundering regulations), and will include documents such as operating manuals
- Processing of application (approx. 2 months)
The entire process usually takes at least 1 year until you are able to start operations.
In order for the registration process to go as smoothly as possible, we highly recommend employing a fluent Japanese speaker with a thorough understanding of Japanese business practice and in particular the funds transfer industry to aid you along the way.
In order to register as a funds transfer operator, you will need to meet the following requirements.
N.B. These are general requirements and do not necessarily reflect the reality of what may be needed for your specific application.
1. Organizational Requirements
・Funds Transfer Service Operators must be either a kabushiki kaisha (Japanese stock company) with a representative based in Japan, or a Foreign Funds Transfer Service Provider with an office in Japan.
・Funds transfers must be registered as part of your business’s operations within the ‘purpose’ section of your Articles of Association (in Japan) or the equivalent document at overseas headquarters.
2. Office Space
・In order to register your business, an actual (i.e. not virtual) office is necessary.
・As Funds Transfer Service Operators deal with clients’ personal information, office space shared with other companies or individual is also prohibited.
・The office must be clearly separate from any living quarters.
3. Financial Requirements
・A performance deposit of at least ￥10m (deposited to the Legal Affairs Bureau).
While there are no specific restrictions regarding capital, many funds transfer businesses in Japan have capital of around 30m. Depending on the scale of your operations, we may recommend that you aim for a figure in this region.
4. Staff & Management
・You must either be or have a representative with an address in Japan.
・For your application to be accepted, you must prove that you have established an internal structure appropriate to handle all the needs of your business and its clients. This includes showing the ability to handle areas such as management, operating practice, compliance, internal audits and IT.
・It is generally not possible for managers to hold more than two of the main posts within the company. Management and operations, however, can be combined.
・There are no restrictions preventing those of non Japanese nationality from holding executive decisions. However, you will be required to demonstrate ample ability to carry out the work involved, including the ability to communicate in Japanese – whether by yourself or through an interpreter/translator.
・For those holding Japanese visas, requirements associated with the visa will also apply (e.g. staying in Japan enough throughout the year and paying taxes correctly).
What are the barriers for overseas corporations registering for Japan’s funds transfer industry?
Seeking to expand to Japan as a pre-existing corporation comes with several advantages. With your business already up and running, and with specialists with existing experience and specialism in the field, you will have a sure advantage in many ways over those registering as an entirely new business from within Japan.
However, there are also significant hurdles which mean that registering as an overseas company generally takes more time than for domestic enterprises. For example:
・Extra time needed to gain approval from decision makers overseas
・Difficulty in understanding Japanese laws and regulations
・Extra time/costs incurred through necessity of interpretation and translation services
For these reasons, we strongly recommend to our clients that they have someone present in Japan who is in charge of the registration process. While there are of course the costs associated with this to be taken into account, in our experience, those companies which make the investment have a smoother, faster and more satisfying experience of the registration process.
No matter where you are applying from, we can support you with registering for Japan’s fund transfer industry. With our All Inclusive Support service, we can also help with establishing your company, gaining any necessary visas, finding an office and more.
*Please be aware that the contents of this site are naturally subject to change, meaning that we cannot guarantee their accuracy at the point of access.
For up-to-date information, please contact us directly.*