FSA warning-letter issuance system for unregistered foreign crypto-asset exchanges (2018-2025)

Wiki route

This entry sits under exchanges index. Read it against FSA crypto-asset exchange registration system — number system / Local Finance Bureau jurisdiction / registration requirements for peer / contrast context and Japan Financial Regulation — Legal Framework for Tokens, Crypto Assets, and Payments for the broader system / regulatory boundary.

System overview

The amended Payment Services Act, effective 2017-04 , prohibited the act of soliciting crypto-asset exchange business to Japanese residents without registration. Against violating foreign operators, the FSA takes a three-stage measure:

1. Warning-letter issuance — written notice, made public by posting on the website
2. Continuous monitoring — multiple issuances against the same operator are also carried out
3. App Store / Google Play removal request (2025+ a new type of measure) — supplementary blocking of domestic access

It has no legal binding force (the limit of extraterritorial application), but the system is designed to block access to the Japanese market.

Warning-letter issuance history (major 8 operators)

Response patterns of warned operators (3 types)

Withdrawal

• Bybit — 2026-03 completely terminated services to Japanese residents
• KuCoin — effectively withdrew

Incorporation (the only route to regularization)

• Binance Holdings → Binance Japan (2022-10 obtained Director-General of Kanto Local Finance Bureau 第00031号 via acquisition of Sakura Exchange)

Continued operation (ignoring warnings)

• MEXC / Bitget / LBank / bitcastle — continued solicitation to Japanese even while warnings continue

Significance of the App Store removal request

The 2025-02 MEXC case is an early instance of the FSA directly requesting Apple/Google to remove an app. It is positioned as an effective measure that supplements the lack of legal binding force of warning letters and achieves access-blocking at the device layer. It is highly likely to become the standard model for handling foreign operators going forward.

Related

• global-vasp-regulatory-comparison-matrix — Global VASP regulatory comparison matrix
• jp-vasp-regulatory-timeline — JP VASP regulatory timeline
• fsa-business-improvement-orders-history — FSA business-improvement order history

来源: 公開情報整理 (FSA「警告書発出先一覧」、金融庁/関東財務局等の警告書公表、各社サイトの WHOIS/アーカイブ確認)

[!note] 2026-05-25 refresh note For the 2025-Q3 / Q4 / 2026 warning rounds following the 2025-04 bitcastle dual warning, re-confirmation against the FSA primary disclosure page has not been completed as of this refresh point (2026-05-25). New additions / timeline extensions will be reflected by directly referring to the FSA “警告書発出先一覧” in an interim refresh before the next review_by (2027-05-19). For the time being, the table treats up to 2025-04 as the official record.