The Complete Guide to Overseas FX Regulations in 2026 | How Long Can Domestic Bank Transfers Be Used? The New Normal of Exit Strategies and Prop Firms

December 18, 2025 Update

“My bank account used for overseas FX transfers was frozen.” “Bank transfers may no longer be usable.”

Since the enforcement of the revised Payment Services Act in June 2025, these voices of concern have been rapidly increasing on social media. In fact, there have been a number of reports of account freezes and usage restrictions from users of GMO Aozora Net Bank and PayPay Bank.

To put it bluntly, overseas FX is not “a thing of the past,” but the “gray zone” that has continued for years is certainly coming to an end.

This article will provide a thorough explanation of the actual situation of account freezes, the legal background, and the three choices that traders should take going forward. Especially for beginners who are about to start trading, we will convey the path with the lowest risk.

【Conclusion】Overseas FX is Not “a Thing of the Past” but the “End of the Gray Zone”

First, let me convey the conclusion of this article.

Overseas FX itself does not become illegal. The Financial Instruments and Exchange Act in Japan regulates the “solicitation activities by unregistered business operators,” and there is no law that punishes traders for using overseas FX.

However, the environment that many traders have enjoyed, where they could easily deposit and withdraw funds through domestic bank transfers, is certainly coming to an end.

Shinjo-kun

What!? So what should people using overseas FX do from now on?

Professor Kaitai

There are three options. Each has its own merits and demerits, so you need to choose one that suits your situation.

3 Options Going Forward

Especially for beginners who are about to start trading, I strongly recommend starting with ② Prop Firms. The reason will be explained in detail later.

【Actual Situation】Why Have Overseas FX Account Freezes Been Rapidly Increasing Since June 2025?

Since late June 2025, posts containing the keyword “overseas FX account freezes” have been rapidly increasing on social media.

According to a survey by Myforex, over 200 posts were confirmed in the first week from June 27, 2025. Most of them expressed concerns such as “Is my account really safe?” and “Will bank transfers no longer be usable?”

Banks with Many Freeze Reports

Reports of freezes and usage restrictions are particularly noticeable at the following online banks:

These online banks were used by many traders due to the ease of account opening and low wire transfer fees. However, their Anti-Money Laundering measures have also been tightened, making remittances to overseas FX more likely to be flagged as “suspicious transactions.”

What Happens If an Account is Frozen

Once an account is frozen, there are serious consequences:

1. Cannot withdraw funds: If the account is used for direct deposit of salary or utility bill payments, it directly impacts one’s life
2. Takes time to unfreeze: It can take 2 weeks to 2 months to unfreeze the account after submitting ID documents and proof of the purpose of transactions
3. May not be unfrozen: The bank may demand account closure if it determines that the account is inappropriate to maintain

Shinjo-kun

Not being able to withdraw funds for 2 months… If my salary deposit account is frozen, I won’t be able to live.

Professor Kaitai

That’s why it’s a golden rule to separate the account used for overseas FX from your living account. However, we need to understand the legal background behind the freezes.

【Legal Background】Understanding the “Three-Tier Structure” That Causes Account Freezes

Account freezes are not caused by a single law. The “three-tier structure” of the Financial Instruments and Exchange Act, the Revised Payment Services Act, and the AML/CFT Guidelines is acting in a complex manner.

Tier 1: Financial Instruments and Exchange Act | Solicitation of Overseas FX Operators is Illegal

At the root of this issue is the Financial Instruments and Exchange Act.

Under Japan’s Financial Instruments and Exchange Act, it is clearly illegal for business operators, regardless of their location, to solicit or provide FX trading services to Japanese residents without registration with the Financial Services Agency.

The Financial Services Agency has been continuously issuing warnings since 2009 and publishing a list of unregistered operators.

However, this gray zone does not protect traders. The fact that they are participating in an illegal transaction with the other party creates the root cause of various risks.

Tier 2: Revised Payment Services Act (Enforced in June 2025) | Stricter Regulation of Payment Aggregators

The Revised Payment Services Act enforced in June 2025 is the direct trigger for the recent surge in account freezes.

The essence of this amendment is that it has clearly defined “cross-border payment aggregation” as a “foreign exchange transaction,” which was previously in a regulatory gray zone.

Previously, payment aggregators did not necessarily require a license to operate their business. However, after the amendment, the target business operators are required to register with the Financial Services Agency and comply with strict KYC (customer identification) and AML (anti-money laundering) measures.

Shinjo-kun

But even if payment aggregators are regulated, doesn’t it have nothing to do with traders?

Professor Kaitai

No, it is greatly related. This amendment does not explicitly order banks to freeze customers’ accounts. However, the “risk score” of all transactions passing through payment aggregators has skyrocketed.

It is extremely unlikely that payment aggregators, whose business model is centered on providing services to operators that the Financial Services Agency considers illegal, will be able to obtain the new license.

As a result, many payment aggregators will either withdraw or be seen as “suspicious” by the compliance departments of banks.

Tier 3: