On July 15, 2016, the Japan Federation of Bar Associations (JFBA) issued new guidance for companies on complying with Japanese and other foreign anti-bribery laws (the “Guidance”). The Guidance comes on the heels of and supplements prior guidelines issued by the Japanese Ministry of Economy, Trade and Industry (METI) in July 2015, clarifying certain aspects of Japan’s foreign anti-bribery laws, as well as guidance on foreign risk management issued by the Small and Medium Enterprise Agency (geared towards facilitating compliance by Japanese small and medium businesses).

While earlier METI Guidelines contained suggestions regarding corporate compliance systems and interpretations of Japan’s foreign anti-bribery law (for example, what constitutes a “foreign public official”), the Guidance is distinct in both the practicality and level of detail it provides to assist companies in crafting and implementing anticorruption compliance policies, responding to potentially corrupt practices, and coping with anticorruption risks in M&A transactions.