Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

Japan Clear all filters
31cases from 1 jurisdiction
€23.5mTotal of monetary amounts (9 cases with an amount)
€9.71mLargest single case: a Japanese electricity utility
€511,488Median per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. Consumer Affairs Agency (消費者庁, CAA) €22.8m 97 % · 18 cases
  2. Financial Services Agency (FSA, 金融庁) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会) €642,643 3 % · 4 cases
  3. Financial Services Agency (FSA, 金融庁) – 0 % · 4 cases
  4. Personal Information Protection Commission (PPC, 個人情報保護委員会) – 0 % · 3 cases
  5. Kanto Local Finance Bureau (関東財務局) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会) – 0 % · 1 case
  6. Ministry of Economy, Trade and Industry (METI, 経済産業省) – 0 % · 1 case

What for?

by area of law

All areas of law

  1. Consumer protection and online retail €22.7m 97 % · 17 cases
  2. Capital markets and financial supervision €642,643 3 % · 8 cases
  3. Environment and sustainability €113,203 0 % · 1 case
  4. Data protection – 0 % · 3 cases
  5. Money laundering and terrorist financing – 0 % · 1 case
  6. Sanctions and export control – 0 % · 1 case

Who?

by sector

All sectors

  1. Energy and utilities €10.2m 44 % · 2 cases
  2. Automotive €7.63m 32 % · 2 cases
  3. Chemicals and pharmaceuticals €4.18m 18 % · 2 cases
  4. Telecoms, IT and software €1.2m 5 % · 3 cases
  5. Financial services and insurance €131,155 1 % · 8 cases
  6. Other €113,203 0 % · 5 cases
  7. Retail and e-commerce €11,506 0 % · 4 cases
  8. Media and online platforms – 0 % · 2 cases
  9. Construction and real estate – 0 % · 1 case
  10. Healthcare – 0 % · 1 case
  11. 1 more€0

When?

per year, by date of decision
Trend
PeriodCasesTotal
20222€11,506
20235€4.29m
202410€17.7m
20257–
20267€1.45m

31 cases

18 Sep 2026 Kinpodo Co., Ltd. (株式会社金宝堂)Kinpodo: order over a bait price 'from 104,500 JPY' for family funerals JapanMisleading advertising and pricing Order

From March to May 2025, Kinpodo advertised family funerals in exclusively rented halls under the name 'Chiisana Mori no Ie' in television commercials at a price 'from 104,500 JPY'. In fact, apart from a few cases, customers had to pay at least 308,000 JPY; the order required a corrective notice, measures to prevent recurrence and cessation.

What organisations can take from it

A 'from' price may only be advertised if customers can realistically obtain it.

Relevance to training and awareness

'From' prices and bait offers

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 2 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Other
Published
18 Sep 2026

Checked against the official source on 4 Oct 2026 · Direct link

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16 Sep 2026 ENECHANGE株式会社ENECHANGE: 91.495 million JPY over overstated revenue in quarterly report and prospectus JapanDisclosure and reporting obligations €511,488

Because revenue had been overstated at the company and its consolidated subsidiary or subsidiaries, the quarterly report for the third quarter of 2023 (filed on 10 November 2023) showed a consolidated loss of 1,382,861 thousand JPY instead of 1,662,516 thousand JPY; the registration statement for a share issue relied on this report, and on 26 February 2024 3,784,200 shares were issued for 3,999,899,400 JPY. After the company admitted the facts and the amount, an administrative monetary penalty (kachōkin) of 91,495,000 JPY was imposed: 1,500,000 JPY for the quarterly report and 89,995,000 JPY for the registration statement.

What organisations can take from it

Revenue recognition at subsidiaries should be scrutinised before any capital increase; an error in a quarterly report becomes many times more expensive through the prospectus.

Relevance to training and awareness

Correct revenue recognition before capital market transactions

Authority / court
Financial Services Agency (FSA, 金融庁) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 172-4 Abs. 2 a. F., Art. 172-2 Abs. 1 Nr. 1, Art. 185-7 Abs. 1 und 14
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Mitigating circumstances
Both partial amounts were halved because the company had filed a report for a reduction before the inspection began (Art. 185-7(14) FIEA).
Published
17 Sep 2026

Original amount 91,495,000 JPY, converted at the ECB reference rate of 16 Sep 2026.

Checked against the official source on 4 Oct 2026 · Direct link

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19 Aug 2026 KDDI株式会社 (KDDI Corporation)KDDI: data protection authority guidance after leak of 12.2 million email credentials JapanData breaches and data security Reprimand or warning

Through a software vulnerability in a mail platform developed by KDDI and provided to several internet service providers, unauthorised parties obtained the credentials (email address and password) of 12,231,954 people; 7,616,173 passwords were stored in plain text, so mailboxes could be read (discovered on 17 June 2026). The authority gave KDDI guidance (shidō) under Art. 147 APPI to improve its technical security measures because access controls against attackers spreading through the system had been inadequate, required a report by 19 October 2026 and also gave such guidance to individual providers responsible for the plain-text storage.

What organisations can take from it

Passwords must never be stored in plain text, and platforms that serve many customers need layered defences against attackers spreading after a breach.

Relevance to training and awareness

Password security and password reuse

Authority / court
Personal Information Protection Commission (PPC, 個人情報保護委員会)
Area of law
Data protection · Data breaches and data security
Legal basis
Act on the Protection of Personal Information (APPI, 個人情報の保護に関する法律) Art. 147, Art. 146 Abs. 1
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Telecoms, IT and software
Employees
10,000 or more
Published
19 Aug 2026

Checked against the official source on 4 Oct 2026 · Direct link

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6 Aug 2026 Snow Corporation; SNOW Japan Co., Ltd. (SNOW Japan株式会社)Snow Corporation and SNOW Japan: orders over undisclosed paid posts on X JapanMisleading advertising and pricing Order

SNOW Japan, to which South Korea's Snow Corporation had left decisions on advertising content in Japan for the jointly offered service, had users of X publish posts about the AI image functions of the 'SNOW' app from April 2025 onwards, for payment and following its instructions, without making the commission recognisable; the posts were treated as advertising by both companies. On 6 August 2026 each of them received an order to stop the display of posts still online, inform consumers and take measures to prevent recurrence.

What organisations can take from it

A foreign provider that leaves its advertising in Japan to a partner remains responsible for undisclosed paid posts.

Relevance to training and awareness

Stealth marketing and disclosure of paid posts

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 3 (Bekanntmachung zu Stealth-Marketing) Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Media and online platforms
Published
6 Aug 2026

Checked against the official source on 4 Oct 2026 · Direct link

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19 Jun 2026 moomoo証券株式会社moomoo Securities: three months without new accounts after false NISA information and AML gaps JapanOrganisational requirements Order

From February to May 2025 the online broker wrongly displayed at least 77 US ETFs and ETNs as eligible for NISA (59 clients traded 25 of them in the tax-advantaged account) and repeated this for a further security after discovery, handled affected clients carelessly and unequally, had since 2024 refused all transfers of holdings to other institutions, carried out no suspicious-transaction assessment for at least 1,531 rejected account applicants and managed cyber and system risks inadequately. Soliciting and accepting new accounts was prohibited from 19 June to 18 September 2026, together with a business improvement order.

What organisations can take from it

A firm that grows fast with account-opening bonuses must scale product approval, complaints handling, suspicious-transaction checks and IT security at the same pace.

Relevance to training and awareness

Accurate product information and suspicious-transaction checks also for rejected clients

Missing or inadequate training played a role in the decision.

Authority / court
Kanto Local Finance Bureau (関東財務局) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 52 Abs. 1, Art. 51; Art. 38 Nr. 1, Art. 43, Art. 40 Nr. 2 FIEA i. V. m. Art. 123 Abs. 1 Nr. 14 Cabinet Office Order on Financial Instruments Business; Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
19 Jun 2026

Checked against the official source on 4 Oct 2026 · Direct link

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11 Jun 2026 GEO Store Co., Ltd. (株式会社ゲオストア)GEO Store: order over a sham deadline in a smartphone buy-back promotion JapanMisleading advertising and pricing Order

GEO Store advertised, among other channels on the official GEO account on X, for example from 12 May to 8 June 2025, a 10% bonus on buy-back prices for used smartphones and tablets that was said to apply only until a certain date. In fact, the same or higher bonuses were available afterwards; the investigation was conducted jointly with the Chubu office of the Japan Fair Trade Commission (JFTC, 公正取引委員会).

What organisations can take from it

Time-limited promotions must actually end – a deadline after which the offer continues unchanged creates artificial time pressure.

Relevance to training and awareness

Time-limited offers and artificial urgency

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 2 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Retail and e-commerce
Published
11 Jun 2026

Checked against the official source on 4 Oct 2026 · Direct link

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12 Mar 2026 Excom Global Co., Ltd. (エクスコムグローバル株式会社)Excom Global ('Imoto no WiFi'): surcharge over unsubstantiated 'No. 1' claims JapanMisleading advertising and pricing €941,067

From February 2020 to May 2024, Excom Global advertised its rental of mobile Wi-Fi routers for travel abroad ('Imoto no WiFi') in travel-guide adverts and on its own websites as number one for customer satisfaction, for being chosen by overseas travellers and for customer service. The commissioned survey, without checking actual use, merely asked for impressions of the websites of the company and nine arbitrarily selected competitors and was also not reproduced accurately; a surcharge of 172,620,000 JPY was imposed.

What organisations can take from it

Anyone advertising survey wins must know and check the methodology – responsibility stays with the advertiser, not the survey provider.

Relevance to training and awareness

'No. 1' claims and rankings

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 8 Abs. 1 i. V. m. Art. 5 Nr. 1 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Fine
Status of proceedings
unknown
Sector
Telecoms, IT and software
Culpability
negligent
Published
12 Mar 2026

Original amount 172,620,000 JPY, converted at the ECB reference rate of 12 Mar 2026.

Checked against the official source on 4 Oct 2026 · Direct link

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23 Dec 2025 Chiba Lotte Marines Co., Ltd. (株式会社千葉ロッテマリーンズ)Chiba Lotte Marines: commitment plan with partial refund after signed-ball promotion JapanMisleading advertising and pricing Other

In a promotional letter of January 2025 for its paid fan club 'TEAM26', the baseball club Chiba Lotte Marines gave the impression that every new member would definitely receive a ball hand-signed by a player at the booth by the stadium, although only some members received one. Instead of an order, a commitment plan was approved on 23 December 2025 – a board resolution, information for consumers, measures to prevent recurrence, allegedly a partial refund of annual fees and reports on implementation; no infringement was thereby established.

What organisations can take from it

Free gifts must state clearly whether every customer or only some will receive them; a commitment plan with refunds can avoid a formal order.

Relevance to training and awareness

Advertising free gifts and special offers correctly

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 30, Art. 31 Abs. 1 und 3 (Zusagenverfahren), Verdacht eines Verstoßes gegen Art. 5 Nr. 2 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Other
Status of proceedings
unknown
Sector
Other
Published
23 Dec 2025

Checked against the official source on 4 Oct 2026 · Direct link

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31 Oct 2025 いわき信用組合 (Iwaki Credit Cooperative)Iwaki Credit Cooperative: lending halt for new clients after payments to anti-social forces JapanOrganisational requirements Order

Among other things, between 2004 and 2011 the credit cooperative had channelled loans taken out in the names of uninvolved people without their knowledge, and via shell companies, to a distressed large borrower group, thereby circumventing large-exposure limits; it had paid large cash sums to anti-social forces (hanshakai-teki seiryoku), carried out no suspicious-transaction assessments and given false reports and false statements to the supervisor. Besides a comprehensive business improvement order, lending to new clients was suspended from 17 November to 16 December 2025, combined with training of all staff away from day-to-day business and the immediate severing of ties with anti-social forces; it was the second order against the cooperative in 2025.

What organisations can take from it

When management and control functions jointly cover up breaches, only a rebuild of governance helps, and every false statement to the supervisor makes the consequences worse.

Relevance to training and awareness

Resisting demands from anti-social forces and truthful information to the supervisor

Missing or inadequate training played a role in the decision.

Authority / court
Financial Services Agency (FSA, 金融庁)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Act on Financial Businesses by Cooperatives (協同組合による金融事業に関する法律) Art. 6 Abs. 1 i. V. m. Banking Act (銀行法) Art. 26 Abs. 1; Art. 10 Nr. 2 und 3 (falsche Berichte und Aussagen); Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Liability of senior managers
Measures against individuals are not set out here.
Published
31 Oct 2025

Checked against the official source on 4 Oct 2026 · Direct link

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17 Oct 2025 NOVA Language Company Co., Ltd. (株式会社NOVAランゲージカンパニー)NOVA: order over waiving an enrolment fee that was never charged JapanMisleading advertising and pricing Order

On the website of its 'NOVA' English schools, NOVA Language Company advertised several courses, for example in September 2024, by waiving an enrolment fee of 22,000 JPY (11,000 JPY for a children's course). The company had not charged anyone such a fee over a considerable recent period; the order required a corrective notice, measures to prevent recurrence and cessation.

What organisations can take from it

A waived charge is only an advantage if it is otherwise actually charged – fictitious fees are misleading price advertising.

Relevance to training and awareness

Advertising price advantages and fee waivers correctly

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 2 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Other
Published
17 Oct 2025

Checked against the official source on 4 Oct 2026 · Direct link

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12 Sep 2025 Japanet Takata Co., Ltd. (株式会社ジャパネットたかた)Japanet Takata: order over comparison with a future 'regular price' for osechi JapanMisleading advertising and pricing Order

From 8 October to 23 November 2024, Japanet Takata offered a two-tier New Year food box ('osechi' for 2025) in its online shop, stating that the 'Japanet regular price' of 29,980 JPY had been reduced by 10,000 JPY to 19,980 JPY, with the regular price presented as applying after the promotion ended. There was no reliable plan to sell at the higher price afterwards; the investigation was conducted jointly with the Kyushu office of the Japan Fair Trade Commission (JFTC, 公正取引委員会).

What organisations can take from it

Anyone advertising against a future price needs a robust sales plan at that price that is actually carried out.

Relevance to training and awareness

Reference prices and discount promotions

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 2 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Retail and e-commerce
Published
12 Sep 2025

Checked against the official source on 4 Oct 2026 · Direct link

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1 Aug 2025 P&G Japan G.K. (P&Gジャパン合同会社)P&G Japan: order over unsubstantiated anti-mould claims for a Febreze product JapanMisleading advertising and pricing Order

P&G Japan advertised its 'Febreze bathroom anti-mould' product (ファブリーズ お風呂用防カビ剤), among other things on the packaging from April 2022 to May 2023, by claiming that simply placing it in the bathroom would prevent black mould for around six weeks. The documents submitted did not substantiate this effect, so the advertising was deemed misleading; the order required a corrective notice, measures to prevent recurrence and cessation.

What organisations can take from it

Anyone promising an effect must hold robust evidence before advertising; without it, the claim is deemed misleading.

Relevance to training and awareness

Substantiating efficacy claims in advertising

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 und 2 i. V. m. Art. 5 Nr. 1 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
1 Aug 2025

Checked against the official source on 4 Oct 2026 · Direct link

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9 May 2025 アストレード株式会社アストレード株式会社: one-year export ban after exports to Russia with a false destination JapanBreaches of sanctions and embargoes Order

Between 17 August 2022 and 5 June 2023, in 18 shipments, the company exported a total of 523 items whose export to Russia is restricted, including motorcycles and personal watercraft, to Russia without the minister’s approval, declaring South Korea as the final destination. Under Art. 53(2) and (3) of the Foreign Exchange and Foreign Trade Act, the company was barred from 16 May 2025 to 15 May 2026 from exporting any goods listed in Appended Table 2-3 of the Export Trade Control Order to any destination, including via third parties. The amount and the facts have not been confirmed against the primary source.

Relevance to training and awareness

End-use checks and circumvention of Russia sanctions

Authority / court
Ministry of Economy, Trade and Industry (METI, 経済産業省)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Foreign Exchange and Foreign Trade Act (外国為替及び外国貿易法) Art. 53 Abs. 2 und 3; Export Trade Control Order (輸出貿易管理令) Anhang 2-3
Action
Order
Status of proceedings
unknown
Sector
Retail and e-commerce
Culpability
intentional
Liability of senior managers
Measures against individuals are not set out here.
Published
9 May 2025

Checked against the official source on 4 Oct 2026 · Direct link

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24 Mar 2025 Tokio Marine & Nichido Fire Insurance, Sompo Japan Insurance, Mitsui Sumitomo Insurance u. a. (4 Unternehmen)Four insurers: orders after customer data were passed on via agencies JapanOrganisational requirements Order

Multi-insurer agencies had forwarded policyholder data to competing insurers, and insurance staff seconded to agencies had sent the agencies’ customer data to their employer without the agencies’ consent; from the agency channel alone, Tokio Marine & Nichido reported 1,004,861, Sompo Japan 799,331, Mitsui Sumitomo 319,915 and Aioi Nissay Dowa 221,144 affected records. The business improvement orders under Art. 132(1) of the Insurance Business Act require a compliance organisation for data protection and unfair competition law, customer data management also at the agencies, stricter rules on secondments, a review by external experts and a fundamental overhaul of the improvement plans submitted after the December 2023 order.

What organisations can take from it

Seconded staff and multi-insurer agencies are data protection risks: customer data may only flow between agency and insurer on a lawful basis.

Relevance to training and awareness

Passing on customer data in sales via agencies

Missing or inadequate training played a role in the decision.

Authority / court
Financial Services Agency (FSA, 金融庁)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Insurance Business Act (保険業法) Art. 132 Abs. 1; Bezug zum APPI (個人情報保護法) und zum Unfair Competition Prevention Act (不正競争防止法)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Published
24 Mar 2025

Checked against the official source on 4 Oct 2026 · Direct link

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26 Dec 2024 株式会社イオン銀行 (AEON Bank, Ltd.)AEON Bank: order over 14,639 unreviewed money laundering alerts JapanSuspicious activity reports Order

Between June and November 2023 and between July and September 2024, the bank failed to assess at least 14,639 transactions flagged by its transaction monitoring for whether suspicious transaction reports were needed, and took up to 152 days on monthly average to file reports (February 2024). It had also not implemented the measures required by the supervisory AML/CFT guidelines by the end-March 2024 deadline and had not remedied findings from the previous inspection. The business improvement order under Art. 26(1) of the Banking Act requires, among other things, the outstanding reviews and reports to be completed and governance by the board and management to be fundamentally strengthened.

What organisations can take from it

Transaction monitoring only works with enough staff to assess every alert promptly; backlogs must reach the board.

Relevance to training and awareness

Prompt handling of monitoring alerts and suspicious transaction reports

Authority / court
Financial Services Agency (FSA, 金融庁)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Banking Act (銀行法) Art. 26 Abs. 1; Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法); Guidelines for AML/CFT der FSA
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Liability of senior managers
According to the reasons, the board and management neither established the facts themselves nor gave instructions despite repeated signals from backlogs, inspection findings and internal audit; the order requires responsibility to be clarified.
Published
26 Dec 2024

Checked against the official source on 4 Oct 2026 · Direct link

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30 Oct 2024 野村證券株式会社 (Nomura Securities Co., Ltd.)Nomura Securities: 21.76 million JPY for layering in Japanese government bond futures JapanMarket abuse and insider dealing €131,155

A person engaged in the firm’s proprietary trading had, on 9 March 2021, repeatedly placed several layered orders in the order book for the long-term JGB future (March 2021 contract) on the Osaka Exchange to create a false impression of active trading, and then bought lower or sold higher. After administrative proceedings were opened, Nomura admitted the facts and the amount; an administrative monetary penalty (kachōkin) of 21,760,000 JPY was imposed, made up of 6,940,000 JPY for the matched volume and 14,820,000 JPY for the excess purchases.

What organisations can take from it

Trade surveillance must detect layering patterns in proprietary trading, including in bond futures and not only in equities.

Relevance to training and awareness

Spoofing and layering in proprietary trading

Authority / court
Financial Services Agency (FSA, 金融庁) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 174-2 Abs. 1 und 8, Art. 159 Abs. 2 Nr. 1; FIEA Enforcement Order Art. 33-13 Nr. 2; Art. 185-7 Abs. 1
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Published
31 Oct 2024

Original amount 21,760,000 JPY, converted at the ECB reference rate of 30 Oct 2024.

Checked against the official source on 4 Oct 2026 · Direct link

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8 Aug 2024 a Japanese fitness companyJapanese fitness company: orders over '24-hour' claims and undisclosed influencer posts JapanMisleading advertising and pricinganonymised Order

The company advertised its gym chain by claiming that add-on services such as self-service teeth whitening, self-service hair removal, massage chairs and workspaces could be used around the clock at no extra cost, although they were only available for a limited number of hours a day (for example five hours for teeth whitening). In addition, the company republished Instagram posts written by third parties for payment as 'customer reviews' on its own website without disclosing that it had commissioned them; both practices were prohibited by two orders on 8 August 2024.

What organisations can take from it

Paid influencer content remains advertising and must be recognisable as such – even when the company later reuses it itself.

Relevance to training and awareness

Labelling influencer marketing and checking service promises

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 1 und Nr. 3 (Bekanntmachung zu Stealth-Marketing) Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Other
Published
9 Aug 2024

Checked against the official source on 8 Oct 2026 · Company name anonymised since 8 Aug 2026 · Direct link

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2 Aug 2024 a Japanese computer manufacturerComputer maker: surcharge for fictitious reference prices in its online shop JapanMisleading advertising and pricinganonymised €261,697

In its own online shop, the manufacturer set a 'WEB price', at which the devices had never been sold there, against a reduced 'campaign price' for seven notebook models, and announced deadlines after which the discounts still applied (example from October 2022: 187,880 JPY reduced to 148,425 JPY, 21% off). A surcharge of 42,230,000 JPY was imposed for this.

What organisations can take from it

Strikethrough prices must be prices actually charged, and promotional deadlines must be honoured – otherwise both are misleading price claims.

Relevance to training and awareness

Strikethrough prices and countdown discounts

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 8 Abs. 1 i. V. m. Art. 5 Nr. 2 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Fine
Status of proceedings
unknown
Sector
Telecoms, IT and software
Culpability
negligent
Published
2 Aug 2024

Original amount 42,230,000 JPY, converted at the ECB reference rate of 2 Aug 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 2 Aug 2026 · Direct link

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24 Jun 2024 a major Japanese bank and two group securities firmsMajor Japanese bank and two securities firms: orders over firewall breaches JapanOrganisational requirementsanonymised Order

The two group securities firms and the bank received business improvement orders; the bank and the group holding company also had to report under the Banking Act. The firms had repeatedly, at one of the securities firms at least 13 times, exchanged non-public client information although the clients had prohibited this or had not consented, and in some cases used such information to win underwriting mandates. The bank also improperly negotiated underwriting allocations for that securities firm and in at least one case made this a condition of a loan agreement.

What organisations can take from it

Information barriers within a financial group need controls that also cover board level and any tying of lending to underwriting business.

Relevance to training and awareness

Handling non-public client information within a financial group

Authority / court
Financial Services Agency (FSA, 金融庁) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 51 und Art. 51-2; Art. 44-3 Abs. 1 Nr. 4 FIEA i. V. m. Art. 153 Abs. 1 Nr. 7 und 8 sowie Art. 40 Nr. 2 FIEA i. V. m. Art. 123 Abs. 1 Nr. 5 Cabinet Office Order on Financial Instruments Business; Art. 33 Abs. 1 und Art. 44-3 Abs. 1 Nr. 2 FIEA; Banking Act (銀行法) Art. 24 Abs. 1, Art. 52-31 Abs. 1
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
A then Deputy President of that securities firm personally received confidential client information from an executive officer of the bank; the orders required responsibility, including that of management, to be clarified.
Published
24 Jun 2024

Checked against the official source on 8 Oct 2026 · Company name anonymised since 24 Jun 2026 · Direct link

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6 Jun 2024 a Japanese medical corporationClinic operator: order over discounts in exchange for five-star Google Maps reviews JapanFake reviewsanonymised Order

The medical corporation promised people attending an internal medicine clinic it operates for a flu vaccination a reduction in the vaccination fee if they rated the clinic with five or four stars on Google Maps. Consumers could not recognise the resulting reviews as advertising prompted by the provider; the order required it to stop displaying them, inform consumers and take preventive measures that also cover the medical staff.

What organisations can take from it

Reviews obtained in exchange for discounts or other benefits are the provider's own advertising and must not appear as independent customer opinions.

Relevance to training and awareness

Stealth marketing and incentivised reviews

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Fake reviews
Legal basis
Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 3 (Bekanntmachung zu Stealth-Marketing) Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Healthcare
Published
7 Jun 2024

Checked against the official source on 8 Oct 2026 · Company name anonymised since 6 Jun 2026 · Direct link

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28 May 2024 a Japanese electricity utilityJapanese utility: surcharge for misleading claims of cheaper electricity tariffs JapanMisleading advertising and pricinganonymised €9.71m

From April 2022 to January 2023, the utility claimed on its website and in a brochure that two household tariffs of one of its tariff plans were cheaper than its standard tariff for households using up to, or more than, 400 kWh a month respectively. Because the fuel-cost adjustment in these tariffs turned out higher, this was not true in some cases; following a joint investigation with a regional office of the Japan Fair Trade Commission (JFTC, 公正取引委員会), a surcharge of 1,655,940,000 JPY was imposed (1,086,170,000 JPY for one tariff, 569,770,000 JPY for the other).

What organisations can take from it

Tariff comparisons must also take variable price components such as fuel-cost adjustments into account; otherwise 'cheaper' becomes a misleading price claim.

Relevance to training and awareness

Price and tariff comparisons in advertising

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 8 Abs. 1 i. V. m. Art. 5 Nr. 2 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Culpability
negligent
Published
28 May 2024

Original amount 1,655,940,000 JPY, converted at the ECB reference rate of 28 May 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 May 2026 · Direct link

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28 Mar 2024 a Japanese internet groupInternet group: formal recommendation after data leak via a contractor’s infected PC JapanData breaches and data securityanonymised Reprimand or warning

After the work PC of an employee at the company’s South Korean security contractor was infected with malware, unauthorised parties accessed its systems from 14 September to 27 October 2023; data of around 520,000 people (users of its messaging service, business partners, employees) were leaked or put at risk. The authority issued a formal recommendation under Art. 148(1) APPI for inadequate organisational security measures (Art. 23 APPI) and required reports until March 2025; in addition, it gave guidance (shidō) under Art. 147 over the possible exposure of user identifiers (GUID) on the group's auction platform.

What organisations can take from it

Contractors’ access to your systems is part of your own security responsibility; an infected machine at a contractor must not become the way in.

Relevance to training and awareness

Malware and contractors’ access rights

Authority / court
Personal Information Protection Commission (PPC, 個人情報保護委員会)
Area of law
Data protection · Data breaches and data security
Legal basis
Act on the Protection of Personal Information (APPI, 個人情報の保護に関する法律) Art. 148 Abs. 1 i. V. m. Art. 23; Art. 147
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Media and online platforms
Employees
10,000 or more
Published
28 Mar 2024

Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Mar 2026 · Direct link

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12 Mar 2024 a Japanese car importerJapanese car importer: surcharge over false standard-equipment claims JapanMisleading advertising and pricinganonymised €7.63m

In 2020 and 2021, the importer listed features as standard in printed and online data sheets and catalogues for three model variants from two model ranges and for an equipment package which were missing or – like certain driver-assistance functions – only worked with a separately ordered navigation package. Two surcharge orders issued on the same day (599,120,000 JPY for the models of one range, 631,850,000 JPY for the models of the other range) total 1,230,970,000 JPY.

What organisations can take from it

Equipment details in catalogues and data sheets are advertising claims and must be checked against the actual standard equipment before publication; a timely self-report can halve the amount.

Relevance to training and awareness

Accurate product information in catalogues and data sheets

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 8 Abs. 1 i. V. m. Art. 5 Nr. 1, Art. 9 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Fine
Status of proceedings
unknown
Sector
Automotive
Culpability
negligent
Mitigating circumstances
For the equipment package on a model of the second range, the amount was halved under Art. 9 because the company had reported the facts itself; a report concerning a model of the first range was not recognised as such a report.
Published
12 Mar 2024

Original amount 1,230,970,000 JPY, converted at the ECB reference rate of 12 Mar 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 12 Mar 2026 · Direct link

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29 Feb 2024 a Japanese homebuilding group and four group companiesHomebuilding group and four homebuilders: orders over 'No. 1' claims without objective survey JapanMisleading advertising and pricinganonymised Order

The holding company of a homebuilding group and four group companies advertised custom-built homes in 2022 and 2023 on websites, in social media posts and in flyers as 'No. 1' in three categories, such as the range of building plots on offer and 'high quality at low cost'. The underlying survey only asked for impressions of selected providers' websites and did not check whether respondents knew the services; on 29 February 2024 a cease-and-desist order was issued against each of the five companies.

What organisations can take from it

Ranking and 'No. 1' claims require an objective survey of actual customers; a website impression test run by a service provider is not sufficient.

Relevance to training and awareness

'No. 1' claims and rankings

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 1 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Construction and real estate
Published
1 Mar 2024

Checked against the official source on 7 Oct 2026 · Company name anonymised since 28 Feb 2026 · Direct link

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26 Dec 2023 four major Japanese insurersFour major Japanese insurers: orders over coordinated premiums in commercial insurance JapanOrganisational requirementsanonymised Order

The four non-life insurers received business improvement orders under Art. 132(1) of the Insurance Business Act because, mainly in co-insurance for corporate clients, they had coordinated premiums and terms among themselves or via agencies, which in the authority’s view is likely to breach the Antimonopoly Act. By 26 December 2023, 576 affected policyholders had been reported; 33% of the cases were committed in the knowledge that they were improper, specific competition law rules of conduct were lacking and training on the subject was inadequate. The orders required further investigation, a competition law compliance organisation and clarification of management responsibility.

What organisations can take from it

Where competitors inevitably interact in co-insurance, sales staff need specific rules and training on what information may be shared.

Relevance to training and awareness

Competition-law-compliant dealings with competitors and agencies

Missing or inadequate training played a role in the decision.

Authority / court
Financial Services Agency (FSA, 金融庁)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Insurance Business Act (保険業法) Art. 132 Abs. 1; Bezug zum Antimonopoly Act (独占禁止法)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Published
26 Dec 2023

Checked against the official source on 8 Oct 2026 · Company name anonymised since 26 Dec 2025 · Direct link

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5 Oct 2023 a Japanese fishing bait manufacturerBait manufacturer: surcharge for unsubstantiated 'biodegradable' claims for fishing bait JapanMisleading environmental and sustainability claimsanonymised €113,203

The bait manufacturer advertised four ranges of artificial fishing bait on packaging, its website and in promotional material – in some cases from April 2016 to February 2023 – as biodegradable even when left behind in the water after use. The company provided no substantiation for this biodegradability; following a cease-and-desist order of 19 December 2022, a surcharge of 17,740,000 JPY was imposed on 5 October 2023.

What organisations can take from it

Environmental claims such as 'biodegradable' only hold with evidence for the specific environment in which the product actually ends up.

Relevance to training and awareness

Greenwashing: substantiating environmental claims

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
Art. 8 Abs. 1 und 3 i. V. m. Art. 5 Nr. 1 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Fine
Status of proceedings
unknown
Sector
Other
Culpability
negligent
Published
5 Oct 2023

Original amount 17,740,000 JPY, converted at the ECB reference rate of 5 Oct 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 5 Oct 2025 · Direct link

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12 Jul 2023 a Japanese carmakerCarmaker: data protection authority guidance after vehicle data was exposed for ten years JapanData breaches and data securityanonymised Reprimand or warning

Because of a misconfigured cloud environment at an affiliated contractor within the group, servers for two of the carmaker's connected-vehicle services were accessible from outside for around ten years; data of about 2.3 million people were affected, including in-vehicle device IDs, vehicle identification numbers and location data. The carmaker had not recognised these data as personal data, as the staff responsible had not been adequately trained, and had not checked the contractor’s access controls. The authority gave the company guidance (shidō) under Art. 147 APPI to improve training, access control and supervision of the contractor and to implement its own remedial measures.

What organisations can take from it

Vehicle identification numbers and locations are personal data too: anyone configuring cloud storage must know this, and contractors’ access settings must be checked.

Relevance to training and awareness

Secure cloud configuration and recognising personal data

Missing or inadequate training played a role in the decision.

Authority / court
Personal Information Protection Commission (PPC, 個人情報保護委員会)
Area of law
Data protection · Data breaches and data security
Legal basis
Act on the Protection of Personal Information (APPI, 個人情報の保護に関する法律) Art. 147 i. V. m. Art. 23 und Art. 25
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Automotive
Employees
10,000 or more
Published
12 Jul 2023

Checked against the official source on 8 Oct 2026 · Company name anonymised since 12 Jul 2025 · Direct link

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27 Jun 2023 a Japanese pizza chainPizza chain: order over an undisclosed service fee in leaflets JapanMisleading advertising and pricinganonymised Order

The pizza chain advertised collection and delivery prices for 953 outlets in leaflets (handed out in store, posted through letterboxes or inserted in newspapers). In fact, between October 2022 and April 2023 – except for telephone or in-store orders during certain periods – a 'service fee' of 4 to 7 per cent of the price, capped at 299 JPY, was added; the order required a corrective notice to consumers, measures to prevent recurrence and cessation.

What organisations can take from it

Mandatory surcharges belong in every price statement – a price to which a fee is added at the end is not a final price.

Relevance to training and awareness

Price statements and hidden extra charges (drip pricing)

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 2 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Food and agriculture
Published
27 Jun 2023

Checked against the official source on 7 Oct 2026 · Company name anonymised since 27 Jun 2025 · Direct link

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11 Apr 2023 a Japanese pharmaceutical manufacturerDrug maker: surcharge for unsubstantiated virus-removal claims for chlorine dioxide products JapanMisleading advertising and pricinganonymised €4.18m

From September 2018 to April 2022, the pharmaceutical manufacturer claimed on packaging, its own website, on television and in adverts on a video platform that products of its brand (room dispensers, clip-on sticks, sprays) remove airborne viruses and bacteria from indoor air by means of chlorine dioxide. The documents submitted did not substantiate this effect and the disclaimers on the packaging did not change the overall impression; the surcharge of 607,440,000 JPY is made up of individual amounts for five product groups, including 452,200,000 JPY for the room dispensers.

What organisations can take from it

Hygiene claims need evidence for the advertised conditions of use; a reference to tests in a closed space does not rescue a sweeping advertising claim.

Relevance to training and awareness

Substantiating efficacy and health claims in advertising

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 8 Abs. 1 und 3 i. V. m. Art. 5 Nr. 1 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Culpability
negligent
Published
11 Apr 2023

Original amount 607,440,000 JPY, converted at the ECB reference rate of 11 Apr 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 11 Apr 2025 · Direct link

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7 Oct 2022 a major Japanese securities firm and its financial holding companySecurities firm: partial ban after propping up prices in block offers and firewall breaches JapanMarket abuse and insider dealinganonymised Order

The securities firm was barred from new block-offer business from 7 October 2022 to 6 January 2023 and received a business improvement order; its parent, a financial holding company, was ordered to take improvement measures. For ten listed shares, the firm had supported the closing price on the block-offer execution date through limit purchases (Art. 159(3) FIEA), its trade surveillance did not act on such single-day transactions, and staff up to executive managing officers exchanged non-public information with the group bank despite clients’ express wishes.

What organisations can take from it

Information barriers between a bank and a securities firm only work if clients’ wishes are enforced technically and organisationally, including against senior management.

Relevance to training and awareness

Information barriers between bank and securities firm; price support in proprietary trading

Authority / court
Financial Services Agency (FSA, 金融庁) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 52 Abs. 1, Art. 51, Art. 32-2 Abs. 2; Art. 159 Abs. 3 FIEA; Art. 44-3 Abs. 1 Nr. 4 FIEA i. V. m. Art. 153 Abs. 1 Nr. 7 Cabinet Office Order on Financial Instruments Business
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
According to the findings, executive managing officers were directly involved in improperly receiving and passing on non-public information; the order required management responsibility to be clarified.
Published
7 Oct 2022

Checked against the official source on 8 Oct 2026 · Company name anonymised since 7 Oct 2024 · Direct link

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16 Sep 2022 a Japanese TV shopping companyTV shopping company: surcharge for unsubstantiated slimming claims in TV shopping JapanMisleading advertising and pricinganonymised €11,506

On 17 March 2019, the TV shopping company promoted a beauty roller using radio-frequency heat and EMS muscle stimulation in a TV shopping programme on BS satellite television, claiming that ten minutes of daily use over three to four weeks would slim the treated body area, such as the waistline. The documents the company submitted did not substantiate this effect, so the advertising was deemed misleading; a surcharge (turnover-based monetary payment) of 1,640,000 JPY was imposed.

What organisations can take from it

Anyone broadcasting efficacy promises for beauty or fitness devices needs robust evidence in advance; small print such as 'results may vary' does not cancel out the overall impression.

Relevance to training and awareness

Substantiating efficacy claims in advertising

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 8 Abs. 1 und 3 i. V. m. Art. 5 Nr. 1 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Fine
Status of proceedings
unknown
Sector
Retail and e-commerce
Culpability
negligent
Published
16 Sep 2022

Original amount 1,640,000 JPY, converted at the ECB reference rate of 16 Sep 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 16 Sep 2024 · Direct link

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