SAKURA Law Office | Legal Update by Managing Partner Kenshiro Michishita
October 1, 2026 (corrected October 16, 2026)
SAKURA Law Office | Kenshiro Michishita, Managing Partner
SAKURA Law Office has published Legal Update No. 29 by Managing Partner Kenshiro Michishita, entitled “Stablecoins and Electronic Payment Instruments in Japan — Issuance and Redemption, Trust Structures, Foreign Issuers, Intermediation, AML/CFT and the 2026 Reforms (2026).”
An analysis that begins by treating every stablecoin as a cryptoasset whose price tracks fiat currency misses the organizing principle of Japanese regulation. Japanese law regulates certain forms of digital money with payment characteristics, including fiat linkage and a promise of redemption at the issue price, as Electronic Payment Instruments, separately from cryptoassets. A business proposing to issue, sell, intermediate, custody or transfer a stablecoin in Japan must therefore establish more than its technical specifications. It must identify who owes the fiat-redemption obligation, which assets support that obligation, against whom a user can enforce a redemption claim, and who is responsible for distribution.
Japan’s Electronic Payment Instruments Service Provider regime took effect in June 2023. Subsequent operating experience and developments in international stablecoin markets led to another amendment of the Payment Services Act in 2025. That Act took effect on June 1, 2026, introducing greater flexibility in managing the reserves of trust-based stablecoins and creating the Electronic Payment Instruments/Cryptoassets Service Intermediary Business. Related implementing changes effective on the same date also expanded the treatment of certain stablecoins constituted as trust beneficiary rights under foreign law. AML/CFT implementation has continued to develop, including the addition of jurisdictions to the Travel Rule framework in August 2026.
At the financial services minister’s press conference on June 26, 2026, the trust-based yen stablecoin announced by the SBI group was described as the first of its kind in Japan and as an initiative capable of improving payments and the usability of tokenized financial products. This illustrates a transition from establishing a legal framework to operating that framework around actual issuance and use.
Drawing on the Payment Services Act, the Act on Prevention of Transfer of Criminal Proceeds, related Cabinet Orders and Cabinet Office Orders, the Financial Services Agency’s administrative guidelines and other published materials available as of October 1, 2026, this Update follows the practical sequence from issuance and redemption to distribution, cross-border operations and AML/CFT. It is intended for financial institutions, trust companies, FinTech and Web3 businesses, payment businesses, overseas issuers, Electronic Payment Instruments Service Providers, General Counsel and investors developing stablecoin businesses in Japan.
Executive Summary
Under Japanese law, fiat-denominated stablecoins satisfying the relevant requirements, including fiat linkage and a promise of redemption at the issue price, are generally analyzed as Electronic Payment Instruments under the Payment Services Act. Tokens that seek price stability algorithmically, or whose redemption arrangements do not satisfy the statutory requirements, may instead fall within the cryptoasset regime or another legal category. The name “stablecoin” does not determine the applicable law.
The framework separates issuance from distribution. Issuance and redemption connect with the banking and funds-transfer rules, while the Specified Trust Beneficiary Right model uses a regulated trust structure. Separately, carrying on the purchase, sale or exchange of Electronic Payment Instruments, or intermediation of those transactions, raises Electronic Payment Instruments Service Provider registration requirements. Since June 2026, a separate intermediary regime has been available for businesses entrusted by an affiliated registered provider that engage only in intermediation and do not accept customer assets.
The reform effective in June 2026 relaxed the previous framework under which the entire backing amount of a trust-based stablecoin was held in qualifying demand deposits, permitting limited investment in qualifying short-dated government bonds and time deposits that allow early termination. The operative order requires qualifying demand deposits to account for at least 50% of the total trust property. Eligible assets, currency, maturity, valuation and shortfall remediation remain regulated. The reform does not permit unrestricted investment of reserves for yield.
A Japanese provider handling a foreign stablecoin must examine the equivalence of the home jurisdiction’s legal framework, the issuer’s redemption capacity, safeguarding and supervision, and the protections that the Japanese distributor can provide. For users other than Electronic Payment Instruments Service Providers and the other excluded categories, the administrative guidelines call for a JPY 1 million limit per user-instructed transfer. They also call for repurchase or equivalent measures where the amount managed for a user exceeds JPY 1 million and the instruments are assessed as unlikely to be transferred. These are not simply a universal holding cap: the covered user and the conditions triggering each measure must be distinguished.
AML/CFT is central to stablecoin operations. Transaction-time customer verification, suspicious-transaction reporting, the Travel Rule and other obligations under the Act on Prevention of Transfer of Criminal Proceeds must be considered. Expansion of the Travel Rule to certain Specified Trust Beneficiary Rights is a separate amendment under Article 2 of Act No. 34 of 2026, promulgated on June 10, 2026, whose commencement is governed by the Cabinet Order mechanism in that Act’s supplementary provisions. It must be distinguished from the addition of foreign jurisdictions that took effect on August 3, 2026.
1. Redemption rights and the issuer’s legal status determine the structure
The decisive question is not whether a token’s market price is close to one yen or one U.S. dollar. It is against whom, under what legal right, in which currency and at what time the user may demand redemption. The Electronic Payment Instruments framework principally addresses money-like value issued by reference to fiat currency and carrying a promise of redemption at the issue price. That legal architecture differs from a cryptoasset whose price happens to remain stable through market trading.
A practical starting point is a single diagram identifying the issuer, redemption obligor, any direct user claim, legal ownership of reserves, insolvency segregation, remittance and retention limits, and transfer mechanics. A functioning smart contract does not resolve an issuer’s inability to redeem, commingling of reserves with general assets, or the absence of an enforceable claim against the relevant obligor. Economic use of the word “stable” is not equivalent to legal protection. The redemption and insolvency architecture should therefore be settled before a code audit is treated as evidence of the product’s legal safety.
Electronic Payment Instruments are not confined to one issuance model. A basic distinction is between digital-money instruments issued through a bank or Funds Transfer Service Provider in connection with funds-transfer transactions and instruments constituted as Specified Trust Beneficiary Rights. In the former, the issuer’s own remittance and redemption obligations and safeguarding of user funds are central. In the latter, the trust property, trustee, beneficiary rights, redemption conditions and beneficiary protection define the arrangement.
These differences affect the business model itself: which entity is the regulated issuer, what property backs the instrument, what is protected in insolvency, and who receives interest or investment income. A company wishing to offer an own-brand stablecoin cannot assume that it may itself become the issuer. The regulated issuer, brand owner, platform operator, distributor or intermediary, and wallet provider should be distinguished, with the authorization and contractual responsibilities of each identified separately.
A trust label does not complete the redemption process. Trust documentation should address creation and cancellation of beneficiary rights, reserve shortfalls, holder-information exchange between trustee and distributor, freezing or correction of mistaken transfers, and provider insolvency. The holder’s rights in the trust property and the system’s ability to give effect to those rights must be assessed together.
2. Reserve flexibility must remain subordinate to reliable redemption
For Specified Trust Beneficiary Right instruments, the earlier model required the full backing amount to be held in qualifying demand deposits with specified banks or other eligible institutions. That structure preserved liquidity and principal security but constrained the issuer’s economics. The 2025 Payment Services Act amendment and implementing rules effective June 1, 2026 replaced it with a framework permitting limited use of qualifying short-dated government bonds and time deposits that allow early termination.
The operative rules are more precise than a policy statement that half of an issue may be invested. Article 3 of the Cabinet Office Order on Electronic Payment Instruments Service Providers sets the relevant ratio at 50% and requires qualifying demand deposits to account for at least that proportion of the total trust property. Only the permitted remainder may be held in qualifying time deposits or eligible government securities, subject to currency and other conditions; eligible bonds must mature within three months of acquisition. The rules therefore do not allow unrestricted reserve investment or use the phrase “50% of the issue amount” as a substitute for the statutory calculation. Reliable face-value redemption remains the governing objective.
Greater reserve flexibility increases the importance of valuation and liquidity management. Where the trust property is invested in the permitted bonds, the trust agreement must require the trustee to value the principal of the trust property at market value and the settlor to eliminate any shortfall below the aggregate amount of the obligations to be performed under the beneficiary rights within two business days counted from the day after the shortfall arises. Maturity, concentration, valuation losses and realization time should therefore be built into redemption stress tests. Contracts and operating procedures must identify funding responsibility, escalation and reporting: compliance with portfolio limits does not by itself ensure that cash will be available when redemption is requested.
The June 2026 ministerial press conference referred to the SBI group’s announced trust-based yen stablecoin as Japan’s first such product. As the framework moves from abstract design to issuance and circulation, issuer credit alone is insufficient. Reserve management, redemption operations, bank accounts, trust administration, cybersecurity, accounting and taxation all contribute to whether the product can function reliably in practice.
3. Separate issuance, distribution and the limited intermediary function
Issuance and redemption are legally distinct from secondary purchase, sale, exchange and intermediation. Even where an issuer lawfully issues an instrument, a third party carrying on its purchase, sale, exchange, intermediation, brokerage, agency or specified custody functions in Japan must consider Electronic Payment Instruments Service Provider registration. Conversely, registration as a distributor does not itself authorize that business to issue its own stablecoin.
The operating model should therefore decompose the roles of issuer, redemption contact, Electronic Payment Instruments Service Provider, bank or Funds Transfer Service Provider, trustee, wallet provider, KYC vendor, merchant and API provider. The legally regulated act performed by each entity must be identifiable. When a customer presses “buy” in an application, the contract, interface and accounting treatment should consistently identify the contracting party, recipient of fiat funds, party transferring the token and party responsible for redemption.
The Electronic Payment Instruments/Cryptoassets Service Intermediary Business regime began on June 1, 2026. It covers businesses entrusted by an Electronic Payment Instruments Service Provider or Cryptoasset Exchange Service Provider to act solely as intermediaries for purchases, sales or exchanges on behalf of that affiliated provider. By restricting the role to intermediation under the provider’s oversight and prohibiting acceptance of customer assets, the regime permits a narrower business model than the full provider-registration framework.
This is relevant to embedding purchase or exchange functions in e-commerce, FinTech applications, corporate treasury tools, payment interfaces and Web3 wallets. However, describing a business as merely providing a screen or connecting an API does not determine its status. The analysis must examine who solicits users, presents terms and receives orders, the remuneration model, customer information, the affiliation agreement and access to user assets. Those facts determine whether the role constitutes intermediation and whether it extends beyond the limited regime into the full provider framework.
4. Foreign distribution and direct issuance to Japanese users require separate analysis
Before handling a foreign-issued U.S.-dollar or other stablecoin, a Japanese Electronic Payment Instruments Service Provider must determine whether the product is eligible for treatment as a foreign Electronic Payment Instrument. The June 2026 reform expanded the treatment of trust beneficiary rights issued under foreign laws providing an equivalent regulatory framework. Regulatory equivalence is therefore an important part of the product analysis, not merely a question of whether the issuer holds a foreign licence.
The review should address redemption duties, reserves, audits or attestations, protection if the issuer fails, supervisory cooperation, sanctions, freezing and technical transfer restrictions. Section I-1-2-3(2) of the administrative guidelines calls for a JPY 1 million limit per user-instructed transfer, including transfers to self-managed wallets, for users other than Electronic Payment Instruments Service Providers and the other excluded categories. Where the amount managed for a user exceeds JPY 1 million, repurchase or equivalent measures concern instruments assessed as unlikely to be transferred. These measures supplement safeguarding obligations; they do not mean that every holding above JPY 1 million is automatically prohibited. The Japanese interface and balance controls must reflect the covered user and actual use.
An offshore issuer directly issuing or redeeming tokens for ordinary users in Japan cannot assume that Japanese issuance regulation is irrelevant because it is overseas. The administrative guidelines state that direct issuance or redemption by a foreign issuer to domestic users, excluding Electronic Payment Instruments Service Providers and the other excluded categories, constitutes funds-transfer transactions in Japan and requires attention to banking-licence or Funds Transfer Service Provider registration requirements. Wholesale dealings with regulated providers should therefore be distinguished from direct provision to ordinary domestic users.
Japanese entry should therefore distinguish a direct issuer-user relationship from a structure in which a Japanese registered provider bears repurchase or redemption exposure. The agreement with the foreign issuer should support the Japanese provider’s safeguarding obligations through workable redemption and indemnity mechanisms. The question is not confined to whether a Japanese-language website exists. Where and by whom issuance, redemption, distribution and custody are performed is central to the regulatory analysis.
A cross-border project may place the issuer, reserve custodian, Japanese distributor, liquidity provider and technology provider in different jurisdictions. The legal map should locate fiat receipt, reserve holding, minting and burning, KYC, customer contracting, redemption and data storage, then apply the relevant financial, sanctions, data-protection and outsourcing rules to each function.
5. AML/CFT, the Travel Rule and controlled smart-contract powers form one operating system
The combination of relatively limited price volatility, round-the-clock transferability, cross-border use and connectivity with DeFi or exchanges creates opportunities for misuse, including money laundering, fraud proceeds and sanctions evasion. In March 2026, FATF published a report addressing stablecoins and unhosted wallets, examining illicit-finance risks and regulatory responses. These risks should be treated as characteristics of the payment system rather than as a separate compliance exercise.
Japanese Electronic Payment Instruments Service Providers must consider transaction-time customer verification, suspicious-transaction reporting and the Travel Rule for covered transfers. Article 2 of Act No. 34 of 2026, promulgated on June 10, 2026, amends Article 10-2 of the Act on Prevention of Transfer of Criminal Proceeds so that the exclusion for Specified Trust Beneficiary Rights is confined to non-bearer rights under a trust providing for beneficiary certificates. The expansion turns on the legal form of the trust, not merely on whether an operator’s holder records are inadequate. Its commencement is governed by a date specified by Cabinet Order within one year of promulgation under the main provision of Article 1 of the amending Act’s supplementary provisions, separately from the penalty changes under Article 1 of the amending Act that took effect on July 10, 2026. It should not be treated as already applicable simply because the Payment Services Act reforms commenced in June; the commencement order and transitional provisions must be checked. The addition of foreign jurisdictions effective August 3, 2026 is a separate change concerning foreign counterparty providers. Product category, transferring entity, counterparty jurisdiction and transaction date therefore require distinct analysis.
A one-time onboarding KYC check is not sufficient. Operating controls should address destination wallets, counterparty providers, unhosted wallets, transaction patterns, blockchain analysis, sanctions lists and fraud reports on an ongoing, risk-sensitive basis. The user terms and systems should support lawful freezing, refusal of transfers and requests for further verification where the circumstances require them.
A stablecoin smart contract may contain blacklisting, freezing, burning, reissuance and other administrator functions. From a decentralization perspective these can appear centralized. Financial regulation and user protection, however, may require controlled intervention in response to fraud, compromised keys, judicial attachment, sanctions, succession, mistaken transfers or redemption. The existence of an intervention function is not, by itself, evidence of an inferior legal design.
That does not justify unrestricted administrator discretion. The documents and code should consistently specify who may freeze, unfreeze, cancel or reissue tokens, on what grounds and with what approval process. They should address multi-signature controls, requests from courts, investigators and users, and preservation of audit logs during an emergency. In some circumstances confidence depends less on absolute irreversibility than on predictable, constrained and reviewable intervention powers.
6. Enterprise use and contracts must connect settlement with enforceable responsibilities
Potential uses extend beyond retail payments to business-to-business settlement, cross-border remittances, round-the-clock transfers, settlement in tokenized-finance arrangements, on-chain collateral management and delivery-versus-payment through smart contracts. The June 2026 ministerial remarks likewise identified the potential for a trust-based yen stablecoin to improve the usability of tokenized financial products.
A corporate treasury adopting the instrument should determine which entity holds received tokens and under what accounting treatment, when redemption into fiat occurs, who bears counterparty credit risk, whether payment is final if a counterparty fails, how mistaken transfers can be addressed and how liquidity will be provided outside normal business hours. Immediate movement on a blockchain is not equivalent to safe and effective corporate settlement.
A stablecoin and a tokenized bank deposit are not necessarily the same legal right merely because they use similar technology. A structure recording a bank deposit through a token should be analyzed by reference to the underlying deposit claim, its protections and its transfer and settlement arrangements. An instrument based on a Funds Transfer Service Provider’s obligation or a trust beneficiary right has different redemption, insolvency and safeguarding consequences. Selection should turn on the acquired right and settlement finality, not shared technology alone.
Stablecoin services commonly involve layered contracts among issuers, trustees, Electronic Payment Instruments Service Providers, limited intermediaries, wallet operators, blockchain providers, KYC vendors, banks and merchants. A structure in which each participant attributes an outage or unauthorized transfer to someone else does not support user protection or continuity of service.
The contracts should cover issuance and redemption, safeguarding, transfer finality, suspension during disruption, forks and network changes, key and administrator control, AML/CFT, information sharing, audit rights, subcontracting, cyber incidents, user remediation, allocation of loss and return of user assets on exit. These matters should be treated as a single life cycle. User terms, inter-party agreements, technical specifications and actual operations should identify the same allocation of responsibility.
Outsourcing cloud infrastructure, wallets, KYC or blockchain analytics does not remove the regulated business’s oversight responsibilities. Contracts should address audit rights, security standards, incident notification, subcontracting, data location, continuity, recovery objectives, access to records and cooperation with regulators. User protection should remain operable if the vendor suspends service or becomes insolvent.
7. Boards should govern stablecoins as financial infrastructure and test the failure scenarios
Confidence in a stablecoin depends on its ability to maintain face-value redemption over time, not merely on growth immediately after issuance. Boards should test reserve liquidity, concentration in banks and trustees, outages, cyberattacks, AML/CFT failures, overseas regulatory events, redemption pressure following rapid issuance growth, reputational shocks and smart-contract failure. Decision-making authority and crisis procedures should be established before those scenarios occur.
Failure testing should include bank or custodian insolvency, network congestion, bridge failure, compromised minting keys, erroneous issuance and distributor failure. Each scenario should identify who suspends activity, who continues redemption, and who can access the required assets and records. Separating transfer-suspension powers from minting, and reserve-movement approval from code upgrades, together with logged and reviewed emergency action, connects legal governance with technical control.
The 2026 reforms can be understood less as unrestricted promotion of stablecoins than as an adaptation of issuance and distribution rules to practical markets while retaining a user-protection foundation. SAKURA Law Office and Managing Partner Kenshiro Michishita consider stablecoin projects to be financial-infrastructure matters spanning banking, funds transfer, trusts, payments, AML/CFT, technology and cross-border law, rather than merely a subtopic of cryptoasset regulation.
Frequently Asked Questions
Q1. Are stablecoins cryptoassets under Japanese law?
Not uniformly. Instruments satisfying the statutory requirements, including fiat linkage and a promise of redemption at the issue price, are regulated as Electronic Payment Instruments. Algorithmic tokens and other instruments outside that definition may instead be cryptoassets or fall within another legal category.
Q2. May an ordinary business freely issue its own yen stablecoin?
Generally, no. Issuance and redemption connect with funds-transfer regulation and require an appropriate regulated issuer or trust structure. An ordinary business may provide branding, technology, use cases and merchant relationships while a regulated financial institution or other appropriately authorized entity performs the issuance function.
Q3. May all reserves of a trust-based stablecoin be invested in government bonds?
No. The operative order requires qualifying demand deposits to account for at least 50% of total trust property. The remainder is limited to qualifying time deposits and eligible government bonds maturing within three months of acquisition, subject to currency and other conditions. Where bonds are used, the trust agreement must also satisfy the market-valuation and shortfall-remediation requirements.
Q4. May a well-known foreign U.S.-dollar stablecoin simply be sold in Japan?
Not without a Japanese analysis. Eligibility as a foreign Electronic Payment Instrument, regulatory equivalence, issuer and reserve quality, redemption arrangements, Japanese registration and safeguarding must be examined. The administrative guidelines also impose constraints specific to foreign instruments, including transfer-related limits.
Q5. Can the foreign issuer simply redeem directly for Japanese users?
The FSA’s guidelines state that direct issuance or redemption by a foreign issuer to domestic users, excluding Electronic Payment Instruments Service Providers and the other excluded categories, involves funds-transfer transactions in Japan and requires attention to banking-licence or Funds Transfer Service Provider registration requirements. Cross-border operation does not by itself avoid issuance regulation. Direct provision to ordinary users must be distinguished from wholesale dealings with regulated providers.
Q6. How does the limited intermediary regime differ from Electronic Payment Instruments Service Provider registration?
The limited regime concerns an intermediary entrusted by an affiliated registered provider that performs only intermediation of purchases, sales or exchanges and does not accept user assets. Custody or functions beyond that limited role require analysis under the full Electronic Payment Instruments Service Provider regime or other applicable rules.
Q7. Does the Travel Rule apply to stablecoins?
The Travel Rule applies to covered transfers by Electronic Payment Instruments Service Providers and other covered persons, not uniformly to every stablecoin or transfer. Article 2 of Act No. 34 of 2026 narrows the Specified Trust Beneficiary Right exclusion to non-bearer rights under a trust providing for beneficiary certificates. That expansion has its own statutory commencement mechanism and is separate from the additional foreign jurisdictions effective August 3, 2026. The product, transferring entity, counterparty and law at the transaction date must be checked.
Q8. Does business-to-business use make regulation inapplicable?
No. Serving corporate customers alone does not remove Electronic Payment Instruments regulation. Customer characteristics, a genuinely restricted use environment, issuance and redemption structure, and the actual activities performed can affect the analysis. B2B projects still need to consider AML/CFT, contracts, accounting and taxation, settlement finality and systems risk.
Q9. Is a smart-contract freezing function legally problematic?
Controlled intervention may be necessary for fraud, sanctions, mistaken transfers or key compromise. The important issues are the legal grounds, responsible persons, procedures and auditability of freezing and unfreezing, consistently reflected in user terms and technical implementation.
Q10. What should be determined first when starting a stablecoin business?
Identify who owes issuance and redemption obligations, what assets support them, who distributes and manages the instrument, and who contracts with Japanese users. Classification, issuer authorization, provider or intermediary registration, AML/CFT, foreign law, smart contracts and commercial documentation should then be designed together.
About the Legal Update Series by Kenshiro Michishita
SAKURA Law Office publishes the Legal Update series through the profile of Managing Partner Kenshiro Michishita, covering corporate law, M&A, cross-border transactions, international disputes, financial regulation, Web3 and cryptoassets, AI and technology, data protection, intellectual property, crisis management and internal investigations. No. 27 addressed the 2026 cryptoasset reforms, and No. 28 examined security tokens. No. 29 focuses on stablecoins and Electronic Payment Instruments as payment and remittance infrastructure, a legal category distinct from cryptoassets and securities.
SAKURA Law Office — Official Website
Kenshiro Michishita, Managing Partner — Profile
How SAKURA Law Office Can Assist
SAKURA Law Office accepts instructions concerning stablecoins and Electronic Payment Instruments, trust-based issuance, provider and intermediary registration, Japanese distribution of foreign instruments, funds-transfer and trust structures, AML/CFT and the Travel Rule, Web3 wallets, settlement connections with tokenized securities, user terms and inter-party agreements, and engagement with the FSA and Local Finance Bureaus. We also work in English with overseas companies and foreign counsel on cross-border projects.
Contact
For advice on stablecoins, Electronic Payment Instruments, digital payments and financial regulation, please contact SAKURA Law Office.
SAKURA Law Office
4F Ark Hills South Tower, 4-5 Roppongi 1-chome, Minato-ku, Tokyo 106-0032, Japan
Kenshiro Michishita, Managing Partner
Web: https://sakura-lawyers.jp/en/
Principal References
1. Payment Services Act — e-Gov Laws (official Japanese text)
2. Act on Prevention of Transfer of Criminal Proceeds — e-Gov Laws (official Japanese text)
3. FSA — Cryptoassets and Electronic Payment Instruments
5. FSA — Electronic Payment Instruments/Cryptoassets Service Intermediary Business (June 1, 2026)
9. Financial System Council — Report of the Working Group on Payment Services System, etc.
10. FSA — Working Group materials: principal issuance regulations for Electronic Payment Instruments
11. FSA — Working Group materials: cryptoassets and Electronic Payment Instruments (stablecoins)
12. FSA — Access FSA No. 259: policy explanation of the payments working-group report
13. FSA — Ministerial press conference referring to the trust-based yen stablecoin (June 26, 2026)
14. FSA — Publication of FATF’s report on stablecoins and unhosted wallets (March 6, 2026)
15. FSA — Additional Travel Rule jurisdictions (July 7, 2026; effective August 3, 2026; English)
17. FSA — Lists of licensed, authorized and registered financial businesses
18. SAKURA Law Office — Official Website
19. SAKURA Law Office — Kenshiro Michishita, Managing Partner
Disclaimer
This article provides general information on stablecoins, Electronic Payment Instruments and digital-payment regulation based on Japanese laws, FSA and other official materials, and general practice publicly available as of October 1, 2026. It is not legal advice or a legal opinion concerning a particular token, issuance, redemption, distribution, intermediary activity, transfer or business. Classification, required issuer authorization, provider or intermediary registration, foreign-instrument requirements, safeguarding, transfer limits, AML/CFT and the Travel Rule, smart-contract powers and user protection depend on the issuance and redemption structure, reserves, contracts, customers, distribution jurisdictions, technical design and other circumstances. Specific projects should be reviewed with appropriate professional advice under the laws, implementing orders, administrative guidelines and other official materials in force at the relevant time. The expansion of the Travel Rule for Specified Trust Beneficiary Rights under Article 2 of Act No. 34 of 2026 must be applied by reference to the commencement mechanism and transitional provisions of that amending Act.