Asset Managers & FinTech Companies Registration Guidebook
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15 Meaning having obtained an equivalent registration as the one under Japanese law for conducting an Investment 16 Notification must be made no later than November 21, 2026, and a Transitional Period Specially Permitted Business may 17 Meaning a natural person having a domicile or residence in Japan and a corporation having its principal office in Japan. 14 When using Transitional Period Specially Permitted Business, it is not allowed to invest 50% or more of the assets under management in domestic shares, etc. with voting rights. Management Business in any of the United States, the United Kingdom, Australia, Singapore, Switzerland, Germany, France or Hong Kong, in accordance with the laws of such country or territory. be conducted for not more than five years from the date of notification. Financial Instrument Business, Type 2 Financial Instrument Business or Investment Management Business is not required when a foreign Investment Management Business Operator (which has been in the industry for three years or more) authorized15 by a foreign authority provides, at a place of business or office established in Japan, (i) discretionary investment services to overseas investors, etc., investment trust services of foreign investment trusts invested in by overseas investors, etc., or management of foreign-based partnership-type fund invested in by overseas investors, etc., in each case currently conducted in such foreign country in accordance with the laws of such country or (ii) with respect to the management referred to in (i) above, offering or private placement of beneficiary certificates of foreign investment trusts, foreign investment securities or foreign-based partnership-type fund interests, or handling thereof, if prior notification16 has been made with regard to certain matters (Article 3-3(1) and(5) of the Supplemental Provisions of FIEA). "Overseas investors, etc." in the context of Specially Permitted Businesses for Overseas Investors, etc. typically includes foreign corporations and individuals, etc. domiciled in foreign countries having all of the following: (i) net assets of 300 million yen or more, (ii) investment financial assets of 300 million yen or more, and (iii) a securities/derivatives account which was opened at least one year ago. "Overseas investors, etc." in the context of Transitional Period Specially Permitted Business refers to foreign corporations or individuals, etc. domiciled in foreign countries. "Non-resident" means a natural person or corporation other than a resident17 (Article 63-8(1)(i) of FIEA, and Article 6(1)(vi) of the Foreign Exchange and Foreign Trade Act), and a non-resident's office in Japan, such as a branch office and local office, is deemed to be a resident regardless of whether the office in Japan has the legal authority to represent the non-resident, even where its principal office is located in a foreign country. Transitional Period Specially Permitted Business h. The Transitional Period Specially Permitted Business14 is a system under which registration as a Type 1 25

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