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Banking in Japan is regulated by the Financial Services Agency (FSA) and the Bank of Japan, operating under the Banking Act (Ginko-ho). Japan's banking sector is one of the world's largest by total assets, and the FSA maintains a rigorous, comprehensive authorisation process designed to ensure systemic stability and consumer protection.
Foreign banks may establish operations in Japan either as a locally incorporated subsidiary (which requires full Japanese banking authorisation) or as a branch of a foreign bank, each pathway carrying distinct capital and governance requirements.
Minimum Capital
JPY 2 billion (approximately USD 13 million) minimum capital for a new domestic bank. Branch operations of foreign banks are subject to separate FSA capital adequacy assessments.
Management Standards
Directors and executive officers must meet FSA standards for competence, integrity, and financial soundness. Japanese banking regulation requires a majority of board members to be independent.
Business Plan and Financial Projections
A detailed business plan covering five-year financial projections, risk management policies, internal audit framework, and IT security infrastructure is required for FSA submission.
Compliance and AML Framework
Applicants must demonstrate compliance with the Act on Prevention of Transfer of Criminal Proceeds and the FSA's AML/CFT supervisory guidelines before authorisation will be granted.
Neptune Fiduciaries provides strategic advisory for institutions seeking FSA authorisation in Japan, covering market entry strategy, entity structure planning, application preparation, and regulatory liaison throughout the authorisation process.
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