Comparative Analysis between the U.S. Executive Order and the Tokyo Prefectural Ordinance against Yakuza - Synchronization of Anti Mafia Activities in Japan, the U.S., and the World

Yasushi Kudo, Attorney at Law, Nagashima, Ohno & Tsunematsu, Japan
Daisuke Takahashi, Attorney at Law, Shinwa General Law Offices, Japan
David N'Guyen, In-house Lawyer, Orange Group, Japan

In July of 2011, the U.S. Executive Order 13581, “Blocking Property of Transnational Criminal Organizations”, listed Japanese Yakuza as one of the significant transnational criminal organizations to whom one must block their property. In October of 2011, the Tokyo Prefectural Ordinance on Exclusion of Boryokudan came into effect in Japan. These regulatory changes and many recent scandals relating to Yakuza are calling for more active and globalized anti mafia activities in Japan, the U.S. and the world. Under these circumstances, how can multinational corporations establish legal compliance and risk management systems that respond to these regulations? This paper will explore some solutions by 1) discussing how to act in response to the Executive Order, 2) comparing the Executive Order and the Tokyo Ordinance, and 3) analyzing the synergy effects of both regulations.

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