Ryosuke Takahashi

Tokyo Osaka

Partner (Attorney)
Tokyo Bar Association

Practice Areas

Financial Regulation (Banking Act, Financial Instruments and Exchange Act, Insurance Business Act, Trust Business Act, Moneylending Control Act, Payment Services Act, Act on the Protection of Personal Information, Act on Prevention of Transfer of Criminal Proceeds, etc.)
Legal Compliance (AML/CFT, antisocial forces, company scandals, whistle-blowing, etc.)
Corporate Law / M&A
Support for start-up companies
Litigation / Dispute Resolution

Biography

1987	Born in Hyogo
Mar. 2006	Kwansei Gakuin Senior High School
Mar. 2010	Kyoto University Faculty of Law (LL.B.)
Mar. 2012	Kyoto University Law School (J.D.)
Dec. 2013	The Supreme Court's Legal Research and Training Institute (66th term)
Jan. 2014	Midosuji LPC
Oct. 2016	Financial Inspector of Inspection Coordination Division, Inspection Bureau, Financial Service Agency (- Dec. 2017)
Jul. 2017	Laws and Regulations Compliance Investigation Office, Financial Services Agency (- Sep. 2018)
Jan. 2018	Expert Inspector of Inspection Coordination Division, Inspection Bureau, Financial Service Agency (- Jun. 2018)
Feb. 2018	Deputy Director of AML/CFT Office, Planning and Coordination Bureau, Financial Services Agency (- Jun. 2018)
Jul. 2018	Expert Inspector of Risk Analysis Division, Strategy Development and Management Bureau, Financial Services Agency (- Sep. 2018) Deputy Director of AML/CFT Office, Strategy Development and Management Bureau, Financial Services Agency (- Sep. 2018)
Oct. 2018	Midosuji LPC Tokyo Office
Jan. 2022	Partner of Midosuji LPC (- present)

Publications

Amendments to laws regarding identification and efforts required of financial institutions (“Banking Practice (Ginko-Jitsumu)” Volume 54 No. 10 (Consecutive Number of Issues: No. 786) p.44), Joint author
Outline of the Financial Services Agency’s Revised “FAQ on Guidelines for AML/CFT” (Financial Law Journal, No. 2233, p.6), joint author
This Is What We Want to Learn! Practices of Financial Services Agency’s Guidelines for AML (from the first installment to the tenth installment) (Financial Law Journal, Vol.2202 to Vol.2220 (serially published in every other installment)), Joint author
(Article-by-Article Explanation) The FATF Recommendations – Countering Financial Crimes in Japan from the Perspective of International Standards (CHUOKEIZAI-SHA HOLDINGS, INC., December 2022), Joint author
6000 Lectures on Legal Measures for Financial Institutions: Volume I Definition and Compliance for Financial Institutions (Kinzai Institute for Financial Affairs, Inc. Feb. 2022), Joint author
Theory and Practice of AML/CFT (Kinzai Institute for Finacial Affairs Inc., Jan. 2022), Joint author
Measures by Banks, etc. to Increase the Sophistication and Efficiency of AML/CFT (Financial Law Journal, Vol.2176, p.37)
Summary of FATF Mutual Evaluation Report of Japan and Operations Required for Financial Institutions (JA Kinyu Homu (JA financial legal affairs) Journal, No.616, Page 4)
Useful for Practical Operations at Bank Branches: Course to Learn about Confirmation at the Time of Transaction and to Increase Sensitivity to
Suspicious Transactions (Economic Legal Research Institute, September 2021, Joint author)
Points of Attention Regarding AML/CFT over Trade Finance based on FATF Guidance (Banking Law Journal 21, Vol. 874, p.4), Joint author
Summary of “FAQ for Guidelines for AML/CFT” (2nd Volume) (Financial Law Journal, Vol. 2163, p.18)
Summary of “FAQ for Guidelines for AML/CFT” (1st Volume) (Financial Law Journal, Vol. 2162, p.36)
Some Considerations Regarding the Regulations on Preservation of User Funds in Funds Transfer Services (New Business Law, Vol.1182, p.51), Joint author
Points of Attention Regarding Identification in Electronic Payment Services in Light of Conduct-Risk (Financial Law Journal, Vol. 2148, p.34)
Considerations for the Confirmation at the Time of Transaction by a Third Party as Provided for in the Act on Prevention of Transfer of Criminal Proceeds (Financial Law Journal, Vol. 2128, p.35)
Utilization of the Guidelines for Management Guarantee based on amendment of the law of obligations (Financial Law Journal, Vol. 2124, p.42)
Looking Ahead to Post FATF Fourth Round of AML/CFT Mutual Evaluations (2nd Volume) (Banking Law Journal 21, Vol. 846, p.30)
Looking Ahead to Post FATF Fourth Round of AML/CFT Mutual Evaluations (1st Volume) (Banking Law Journal 21, Vol. 845, p.23)
Introduction of eKYC due to the revisions of the enforcement regulations of Act on Prevention of Transfer of Criminal Proceeds and the Ministerial Ordinance on Foreign Exchange (Banking Law Journal 21, Vol.838, p.4)
Regulation trends over AML/CFT and response by using three lines of defense (2nd Volume) (Banking Law Journal 21, Vol. 836, p.18)
Regulation trends over AML/CFT and response by using three lines of defense (1st Volume) (Banking Law Journal 21, Vol. 835, p.4)
Practical operations under the risk-based approach, such as risk assessments by a specified business operator, etc. (Financial Law Journal, Vol. 2099, p.34)
Guidelines for AML/CFT practices and efforts in the trust bank industry (Shintaku Forum, Oct. 2018, p.60)
Outline of “Guidelines for AML/CFT” and points to remember in money transfer transactions (Banking Law Journal, Vol. 21, No. 828, p.4), Joint author
Outline of “Guidelines for AML/CFT” (Financial Law Journal, Vol. 2084, p.8), Joint author
Enhancement of AML/CFT practices (Shinkumi, Dec. 2017, p.4), Joint author
Importance of risk-based approach in AML/CFT (Financial Affairs, Vol.3236, p.39), Joint author
Actual Practice in Customer Management Based on the Revised “Guidelines for AML/CFT” (Financial Law Journal, Vol. 2114, p.13)

Lectures

Challenges and Solutions for AML/CFT/CPF measures in the Real Estate, Asset Management, and Jewelry & Precious Metals Industries (Nikkeisha, Inc., September 2025)
Fintech Compliance Meetup: Focusing on AML/CFT (Fintech Association of Japan, September 2025)
Overview of Economic Sanctions Measures and Risk-based Arrangements therefor in Japan (Dow Jones (Japan) K.K., February 2025)
AML/CFT Measures Required to be Taken by judicial scriveners (Shiho-Shoshi lawyers) (Kita-Shibu Osaka Shiho-Shoshi Lawyer’s Association, January 2025)
Group Management Governance and Roles of Company Auditors (Regional Banks Association of Japan, April 2024)
Recent Topics on AML/CFT and Practical Operations Required for Securities Companies (Japan Securities Dealers Association, November 2023)
Basis and Latest Trend of AML/CFT/CPF (for Fintech Service Providers) (KYC Consulting Corporation, October 2023)
Impact of Law in Response to FATF Recommendations on Financial Practices – Focusing on the Revision of the Act on Prevention of Transfer of Criminal Proceeds and the Foreign Exchange and Foreign Trade Act – (Seminar Info Co., Ltd., September 2023)
Issues Concerning Transparency of Corporations and Legal Arrangements and Management of Substantial Controlling Person (Association of Certified Anti-Money Laundering Specialists (ACAMS), September 2023)
Considering Concrete Measures to Complete Appropriate Arrangements for AML (for JA Management) (Economic Legal Research Institute, September 2023)
Arrangements based on Guidelines for AML/CFT – Roles Required for Regional Financial Institutions – (ACSiON, Ltd., August 2023)
Recent Topics on AML/CFT and Practical Operations Required for Securities Companies (DSB Co., Ltd., June 2023)
Current Circumstances Surrounding Regional Banks and Roles of Internal Audit (Regional Banks Association of Japan, May 2023)
Thorough Explanation on AML/CFT/CPF Required by Financial Institutions and DNFBPs (Nikkei Inc. and Nikkei Media Marketing Inc., May 2023)
Recent Topics on AML/CFT/CPF (KPMG AZSA LLC, February 2023)
AML/CFT/CPF Required by the Financial Services Agency’s Guidelines – Practical Operations to Complete Arrangements by March 2024 (Dow Jones (Japan) K.K., December 2022)
Practical Operations of AML/CFT at Securities Companies (Japan Securities Dealers Association, November 2022)
AML/CFT/CPF for 2024 (Seminar Info Co., Ltd., October 2022)
Book Launch Seminar of “Theory and Practice of AML/CFT” (Kinzai Institute for Financial Affairs, Inc., April 2022)
KYC/CDD: Best Practice for Identifying the Rising Financial Crime Risks in Japan (Association of Certified Anti-Money Laundering Specialists (ACAMS), April 2022)
How to Conduct Ongoing Customer Due Diligence Based on “AML/CFT/CPF Action Plan” (NTTCom Online Marketing Solutions Corporation, March 2022)
AML/CFT at Financial Institutes Based on FATF Mutual Evaluation Report of Japan – Act Amendments for Follow-up Evaluations and Prospects for Administrative Actions by the Authorities – (Seminar Info Co., Ltd., October 2021)
AML/CFT at Securities Companies Based on FATF Mutual Evaluation Report of Japan (Japan Securities Dealers Association, October 2021)
Practical Responses to and Points of Attention Regarding the Amendments of the Act on the Protection of Personal Information and the Whistleblower Protection Act (Regional Banks Association of Japan, September 2021)
(Panel Session) Digital Footprints: Changes in the KYC Process and Customer Due Diligence in the Era of Virtualization (Association of Certified Anti-Money Laundering Specialists (ACAMS), September 2021)
Future Risk Management Required by the Amendment of Guidelines for AML/CFT (Sansan, Inc., July 2021)
Points to Note Regarding Digital Transactions, such as Electronic Contracts on Credit (Japan Consumer Credit Association, May 2021)
AML Seminar (for Fund Transfer Services) (NTT DATA Getronics Corporation, May 2021)
Practical Operations of AML/CFT Based on Revised AML/CFT Guidelines and FATF Fourth Round of AML/CFT Mutual Evaluations (Financial Management Forums, Inc., May 2021)
Practical Responses to “Guidelines for preventing unauthorized access, etc. in internet transactions” (ACSiON, Ltd., April 2021)
AML/CFT at Financial Institutions After FATF Fourth Round of AML/CFT Mutual Evaluations – Risk-Based Approach Taking into Account FATF and the Authorities’ New Point of View – (Seminar Info Co., Ltd., February 2021)
Amendment of “Guidelines for AML/CFT” and Practical Operations Required for Financial Institutions (Nikkei Inc., January 2021)
Practical Operations in Management of Foreigers’ Period of Stay (ACSiON, Ltd., December 2020)
Practical Operations in Continuous Customer Management Considered from the Authorities’ Point of View (ACSiON, Ltd., June 2020)
Future Trends and Practical Operations of AML/CFT Based on the Feedback about FATF Fourth Round of AML/CFT Mutual Evaluations – Risk-Based Approach in View of Act Amendments and Administrative Actions Expected in the Future – (Seminar Info Co., Ltd., February 2020)
Toward FATF Fourth Round of AML/CFT Mutual Evaluations(DBS Bank TokyoBranch, July 2019)
Completion of AML/CFT Required Now Taking into Account the FATF Fourth Round of AML/CFT Mutual Evaluations in 2019 (Economic Legal Research Institute, July 2019)
Current Situation and Challenges for AML/CFT in Japan (Japan Corporate Governance Network, May 2019)
AML/CFT at Financial Institutions Taking into Account FATF and the Authorities’ Point of View: Practical Operations Using Risk-Based Approach and the Framework of Three Lines of Defense (Seminar Info Co., Ltd., February 2019)
Introduction of eKYC due to the revision of the enforcement regulations of Act on Prevention of Transfer of Criminal Proceeds (Blockchain Collaborative Consortium, December 2018)
Recent Trends in Financial Administration and Risk-Based Approach (Regional Banks Association of Japan, November 2018)
Current Situation and Challenges for AML/CFT (SCSK Corporation, September 2018)
Current Situation and Challenges for Compliance Posture Seen through Financing Monitoring (Kinzai Institute for Financial Affairs, Inc., July 2018)
Efforts by Financial Services Agency, The Japanese Government, for AML/CFT (NTT DATA Getronics Corporation, June 2018)
Guidelines for AML/CFT (The Shinkumi Federation Bank, April 2018)
Sophistication of AML/CFT at Financial Institutions (Seminar Info Co., Ltd., February 2018)
Guidelines for AML/CFT (SCSK Corporation, February 2018)
Guidelines for AML/CFT (The Second Association of Regional Banks, February 2018)
Proposed Guidelines for AML/CFT and Response Taking into Account the FATF Fourth Round of AML/CFT Mutual Evaluations (Japan Payment Service Association, January 2018)
How to respond to “FATF Fourth Round of AML/CFT Mutual Evaluations” and “AML/CFT” (Kinzai Institute for Financial Affairs, Inc., December 2017)
Toward FATF Fourth Round of AML/CFT Mutual Evaluations (Regional Banks Association Of Japan, September 2017)

Activities

Financial Transaction Law Group, Tokyo Bar Association
Associate member of Japan In-House Lawyers Association
2021 Member of the Expert Committee on “Investigations of Risk Assessment and Publicity / Public Relations Regarding Non-profit Organizations for Compliance with the FATF Recommendations” Established by the Cabinet Office

Languages

Japanese / English

Practice Areas

PERSONAL INFORMATION AND PRIVACY RISK MANAGEMENT AND RESPONSE TO SCANDALS DIGITAL TECHNOLOGY VENTURE BUSINESSES MERGERS AND ACQUISITIONS(M&A) BANKING AND FINANCE TRANSACTIONS

Our People(All)