The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement

Establishing a FIBO Presence in Japan • In order to conduct regulated activities as a FIBO in Japan, a registered presence in Japan is required for most substantive activities. • There are a number of forms that this presence may take, both as Japanese and non-Japanese entities. • Once a presence is registered, staffing and other organizational tasks are required. • The four major FIBO registrations follow a relatively similar path through the following phases: 1. Initial draft of the application; 2. Discussions with the regulators and amendments to the application; 3. Formal submission of the application; 4. Formal reviewing period and formal review of the application; and 5. Completion of the registration. Morgan Lewis 25

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