1 Our policy
The Norinchukin Bank (“The Bank”) does not facilitate any transactions —whether direct or indirect—that violate or may potentially violate economic sanctions regulations stipulated under Japan’s Foreign Exchange and Foreign Trade Act (hereinafter referred to as the “FEFTA”), regulations imposed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (hereinafter referred to as “OFAC,” an agency that implements measures such as transaction prohibitions and asset freezes against countries, regions, individuals, and entities designated by the United States for foreign policy and national security purposes), as well as economic sanctions laws and regulations of applicable countries and regions, or United Nations sanctions resolutions in order to appropriately comply with economic sanctions regulations where we conduct business activities. Furthermore, transactions intended to circumvent such sanctions are also strictly prohibited. Customers engaging in foreign exchange transactions are kindly requested to ensure and confirm that their transactions do not fall under these prohibitions before submitting any requests.
2 Applicable Transactions
●Transactions Subject to OFAC Regulations
The Bank does not process the following transactions under our policy, regardless of whether they are direct or indirect, or the currency involved:
- Transactions that directly or indirectly involve locations or surrounding regions that include (Iran, North Korea, Cuba, Crimea, the self-proclaimed Donetsk People’s Republic / Luhansk People’s Republic).
- Transactions in which the governments of sanctioned countries (Iran, North Korea, Cuba, Crimea, the self-proclaimed Donetsk People’s Republic / Luhansk People’s Republic) or their government officials are directly or indirectly involved.
- Individuals residing in comprehensively sanctioned countries or regions, and companies located or headquartered in such countries or regions.
- Transactions directly or indirectly involving sanctioned persons such as entities or individuals engaged in the proliferation of weapons of mass destruction, terrorism, drug trafficking, or transnational organized crime, as well as transactions conducted on behalf of such sanctioned persons.
- Sanctioned persons also include those designated under Belarus sanctions (including government-related and state-owned enterprises), Myanmar sanctions (including military and defense-related enterprises and state-owned enterprises), Russia sectoral sanctions, and other individuals, corporations, organizations, or vessels specifically designated, as well as those owned or controlled by them.
●Transactions Subject to FEFTA Regulations
The Bank confirms that customers’ foreign exchange transactions do not fall under regulated transactions under the Foreign Exchange and Foreign Trade Act (FEFTA), including those related to North Korea, Iran, Russia, and Belarus.
3 Response Policy when Applicable
- Even after facilitating a transaction, if it is determined that the transaction may violate OFAC regulations or other economic sanctions laws, we may block the transaction.
- If assets are blocked due to OFAC regulations, we will not be able to return any funds deposited as payment for the transaction. In such cases, you will be required to take appropriate action yourself, such as applying to OFAC for the release of frozen assets. Please be aware of this in advance.
- If a review becomes necessary due to the possibility of violating economic sanctions laws, please note that submission of required documents and the determination of whether the transaction can be processed may take additional time.
(As of October 29, 2025)