Japan Anti-Social Forces: AML Screening Requirements (2026)

Japan expects businesses to sever relationships with Anti-Social Forces (ASF) and avoid providing them with funds and other benefits. Businesses in Japan therefore need to manage ASF risk both at onboarding and throughout the relationship. The rules come from several sources at once: government guidance, legislation, local ordinances, and financial sector supervision.

Interaction with ASF poses a significant risk to businesses in the country. According to Japan’s 2025 National Risk Assessment follow-up report, 164,086 suspicious transaction reports submitted from 2022 to 2024 cited reasons related to organized crime groups, representing 7.7% of the total.

In this guide, we'll explain Japan's ASF framework, who must conduct ASF screening, how businesses can identify ASF risks, and the compliance measures required to meet regulatory expectations.

What are Anti-Social Forces in Japan?

Anti-Social Forces (ASF), or hanshakai-teki seiryoku, is a general term for groups or individuals that threaten civil society through violence, intimidation, fraud, or other methods, such as the yakuza, also known as the Japanese mafia.

Organizations commonly considered anti-social forces

The best-known anti-social forces are Japan's organized crime syndicates, usually called yakuza outside official contexts. Japanese police and legislation call the same groups bōryokudan ("violent groups"), a term the syndicates themselves reject. Within that population, groups formally designated under the Anti-Boryokudan Act are classed as shitei bōryokudan, or "designated organized crime groups." ASF as a category is broader than the syndicates alone.

Japan’s National Police Agency (NPA) currently classifies six groups as “major organizations”: Yamaguchi-gumi, Sumiyoshi-kai, Inagawa-kai, Kobe Yamaguchi-gumi, Kizuna-kai, and Ikeda-gumi. 

Yamaguchi-gumi, Sumiyoshi-kai, and Inagawa-kai are the historically dominant “big three” and remain the largest. Kobe Yamaguchi-gumi split from Yamaguchi-gumi in 2015. Kizuna-kai later emerged from a Kobe Yamaguchi-gumi splinter, while Ikeda-gumi left Kobe Yamaguchi-gumi in 2020.

ASF can also include former members, associates, affiliated or front companies, corporate racketeers, extortion networks, groups exploiting political or social causes, and other criminal organizations.

The NPA calls loosely structured networks tokuryū, which is a name combining tokumei (“anonymous”) and ryūdō (“fluid”). These groups hide their organizers, recruit participants through social media and job sites, and repeatedly form and disband. The 2024 Annual Report by JAFIC—Japan’s Financial Intelligence Center, the country’s FIU—notes that the National Risk Assessment Follow-up Report replaced the “online and telephone fraud group” with this category and added social media investment and romance fraud.

The NPA’s 2025 organized crime report recorded more than 10,000 people apprehended in fundraising crimes believed to involve these groups, and identified links to current and former bōryokudan members. Meanwhile, bōryokudan members and associates fell by 1,200 to a record low of 17,600, the twenty-first consecutive annual decline. Because tokuryū networks lack stable names and memberships, ASF controls cannot rely solely on syndicate lists.

A counterparty may have no obvious gang affiliation while still being controlled or used by ASF. Screening must therefore cover beneficial owners, directors, representatives, and connected companies.

Why Japan has no legal definition of ASF

There is no single exhaustive statutory definition of anti-social forces. The 2007 government Guidelines for How Companies Prevent Damage from Anti-Social Forces describe the concept in terms of both a person or group’s attributes and their conduct, while specific laws and ordinances define categories such as bōryokudan, bōryokudan members, and people closely connected to them.

The absence of an exhaustive legal definition means that, if ASF screening or assessment is undertaken or required, it should not be limited to formal bōryokudan status but should also consider relevant affiliations and conduct, including futō yōkyū (“violent or unjust demands”). 

Japan’s ASF legal and regulatory framework

Several instruments work together, each covering a different part of the picture.

• Guidelines for How Companies Prevent Damage from Anti-Social Forces (2007). This is government guidance rather than law. It sets out what every company is expected to do to avoid dealing with organized crime, and established the ASF declarations and exclusion clauses now standard in Japanese commercial contracts.
• Anti-Boryokudan Act. It allows prefectural public safety commissions to formally designate organized crime groups. Members of a designated group can then be ordered to stop making “violent or unjust demands” on businesses.
• Prefectural bōryokudan exclusion ordinances. These restrict companies from providing benefits to organized crime groups and give the exclusion clauses local legal backing. Every prefecture has one, though specific requirements vary.
• Act on Prevention of Transfer of Criminal Proceeds (APTCP). This act sets customer due diligence, recordkeeping, and suspicious transaction reporting duties for specified business operators. These are anti-money laundering obligations rather than ASF rules, but the two overlap in practice.

There’s also JAFIC (FIU), which collects and analyzes suspicious transaction reports. 

In the background, FATF assesses the framework as a whole. Following its 2021 mutual evaluation, Japan entered into enhanced follow-up and then passed legislation in December 2022 amending several laws, including the APTCP. FATF's third enhanced follow-up report in October 2024 recognized further progress. Japan is currently rated “compliant” on 4 Recommendations and “largely compliant” on 35, with none rated “partially compliant”.

Who needs ASF screening?

In practice, any business operating in Japan. What varies is where the obligation comes from and how demanding it is.

For companies generally, the baseline is a 2007 government document, the Guidelines for How Companies Prevent Damage from Anti-Social Forces. These are guidance rather than law, setting out what the government expects every company to do to avoid dealing with organized crime. Two things give them practical force. All 47 prefectures have passed bōryokudan exclusion ordinances restricting the provision of benefits to organized crime groups. And Japanese commercial contracts routinely carry ASF declarations and exclusion clauses, so counterparties end up checking each other by default.

Financial institutions face a higher bar. The Financial Services Agency (FSA) is Japan's financial regulator, supervising banks, insurers, securities firms, payment and funds transfer providers, and crypto asset exchange service providers. Its AML/CFT Guidelines set out what it expects those firms to do, and the accompanying FAQ treats a database covering Japanese anti-social forces as one of the reliable sources a firm should use to detect high-risk customers, alongside Politically Exposed Persons (PEP) data and sanctions lists.

It helps to keep ASF exclusion separate from anti-money laundering. Under the APTCP, a broader set of "specified business operators," including real estate brokers, money lenders, and crypto exchanges, must verify customers, keep records, and file suspicious transaction reports. Those are AML duties rather than an ASF screening mandate, even though the two overlap heavily in practice.

For fintechs, the first question is which category the product falls into. A payment service, a funds transfer service, and a crypto asset exchange each pull in a different set of obligations.

One gap a global program will not close: sanctions and PEP lists rarely name domestic bōryokudan associates, front companies, corporate racketeers, or the anonymous and fluid criminal groups the police have tracked as a separate category since 2023. Japan-specific ASF screening has to run as its own layer.

Suggested reading: Japan’s Crypto Future Under Takaichi: Why the FSA, Not Politics, Will Shape Regulation in 2026

Practical steps for managing ASF risk 

Japan does not prescribe an official legal compliance test.

1. Establish an ASF compliance framework. Adopt internal policies, assign responsibilities, train employees, and define escalation procedures.
2. Assess and screen ASF risk. Conduct risk-based KYC and KYB, identify beneficial owners and controllers, and perform ASF screening before onboarding and throughout the business relationship.
3. Implement appropriate controls. Include ASF representations and termination clauses in contracts where appropriate, maintain records, investigate alerts, and monitor customer activity.
4. Review, report, and improve. Escalate potential ASF matches, file any required reports where legal thresholds are met, and periodically review and update your ASF compliance program.

The steps above are not exhaustive. Businesses should consider their own circumstances before implementing any recommendations.

Consequences of non-compliance with ASF requirements  

Japan does not impose a single uniform nationwide penalty solely because a business unknowingly enters into a relationship with an ASF-linked party.  Depending on the rule breached, consequences may include regulatory orders or license-related action, measures under prefectural ordinances, contract termination, civil disputes, and reputational harm. Consequences may become more serious if the business knowingly continues the relationship after discovering an ASF connection.

How to detect anti-social forces

Effective anti-social forces controls in Japan combine identity and ownership verification, database checks, adverse media checks, transaction monitoring, and human review. Searches should cover aliases, addresses, and corporate connections, as well as screening for names expressed in different Japanese writing systems, such as kanji, kana, or romaji.

Anti-social forces list: Japan police database

Japan does not have a public, definitive national ASF list. The NPA supports restricted information-sharing in specific contexts. On January 4, 2018, the Japanese Bankers Association announced that banks had begun connecting to the police bōryokudan information database through the Deposit Insurance Corporation of Japan to check new personal loan applicants. This is a restricted banking channel, not a public ASF database available to businesses in general.

Anti-social forces databases and exclusion lists

Businesses may combine commercial ASF databases, industry-association systems, and their own records. Coverage varies between sources and sectors, so businesses should assess whether the sources they use are sufficiently reliable, current, and appropriate for their applicable risk and regulatory requirements. If a credible match also raises suspicion of criminal proceeds or money laundering, a business subject to the APTCP reporting requirements may need to file a suspicious transaction report through its competent authority. The report is then collected and analyzed by JAFIC.

Adverse media checks explained

Adverse media screening searches credible public sources for organized crime, coercion, fraud, money laundering, or hidden corporate links. Analysts should determine whether the reporting is reliable, current, and genuinely relates to the customer, and check for subsequent corrections, acquittals, or other developments. For FSA-regulated financial institutions, negative media may be a high-risk indicator, but it should not be treated as equivalent to a confirmed ASF classification without further assessment. 

Japanese adverse media providers: Pros and cons

Local providers may offer better Japanese-language and local coverage, strengthening KYC checks in Japan. However, they may have limited international reach or fewer integrations. Adverse media screening still needs manual review for common names and ambiguous reporting.

Global adverse media providers: Pros and cons

Global services can combine an adverse media check with PEPs, sanctions, and cross-border data, but may miss local subtleties or Japanese name variants. Businesses should therefore establish which Japanese sources a provider monitors and how its system handles these name variations.

Japanese and global adverse media providers compared 

Suggested reading: KYB and KYC in 2026: Complementary Pillars of Trust in a Complex Financial System

PEP and sanctions screening for ASF risk

PEP and sanctions screening address different risks from ASF screening and should run alongside it. A PEP is not automatically ASF, and the absence of a sanctions match does not clear ASF risk.

Suspicious transaction reporting requirements

Businesses subject to the APTCP reporting must file suspicious transaction reports through their competent authority when they suspect criminal proceeds or money laundering. An ASF connection does not automatically require an STR, but should be assessed to determine whether the statutory suspicion threshold is met. JAFIC then collates and analyzes reports.

KYC and KYB checks for Japanese clients

A risk-based KYC process in Japan should verify the customer, establish the purpose of the relationship, assign a documented risk rating, and conduct ASF, PEP, and sanctions screening. 

For companies, know your business (KYB) checks in Japan should confirm registration, actual business activities, representatives and their authority, beneficial owners, controllers, and relevant affiliates. Higher-risk clients may require additional checks on the sources of their funds or wealth, as well as enhanced monitoring. Businesses should retain verification and decision records, monitor activity against the client’s expected profile, and update information and screening periodically according to risk, as well as when ownership, management, activities, or other material circumstances change. 

Key takeaways on Anti-Social Forces compliance

Anti-Social Forces extend beyond the yakuza to include affiliated individuals, businesses, and other criminal organizations and networks. Rather than relying on a single law, Japan's ASF compliance framework is built on a combination of national legislation, local ordinances, government guidance, regulatory expectations, and contractual safeguards.

There is no single public or definitive police list that businesses can rely on to identify ASF exposure. Instead, organizations should take a risk-based approach, combining KYC and KYB, commercial screening databases, adverse media, PEP and sanctions screening, transaction monitoring, and other relevant risk indicators. Potential ASF matches should be assessed through evidence-based human review, with clear documentation supporting each decision and ongoing reassessment throughout the customer relationship.

Glossary of Japanese ASF terms

• Anti-Social Forces / hanshakai-teki seiryoku (反社会的勢力): An umbrella risk concept covering people and organizations that threaten civil society through violence, intimidation, fraud, or similar conduct.
• Hansha (反社): A commonly used abbreviation for hanshakai-teki seiryoku.
• Yakuza (ヤクザ): A widely used, non-statutory term for Japan’s traditional organized crime syndicates and their members.
• Bōryokudan (暴力団): The term used in Japanese policing and legislation for organized crime groups, literally meaning “violent groups.”
• Shitei bōryokudan (指定暴力団): A bōryokudan formally designated by a prefectural public safety commission under the Anti-Boryokudan Act.
• Bōryokudan-in (暴力団員): A member of a bōryokudan.
• Tokuryū (トクリュウ): An abbreviation for tokumei-ryūdōgata hanzai gurūpu (匿名・流動型犯罪グループ), meaning “anonymous and fluid criminal groups.”
• Sōkaiya (総会屋): A corporate racketeer who uses disruption, threats, or sensitive information to extort companies, traditionally through shareholder meetings.

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