Updated
“The bank account I was using to send money overseas for FX has been frozen.” “I may not be able to use bank transfers anymore.”
Since the enforcement of the revised Payment Services Act in June 2025, these anxious voices have been rapidly increasing on social media. In fact, there have been a succession of reports of account freezing and usage restrictions from users of GMO Aozora Net Bank and PayPay Bank.
To put it bluntly, overseas FX is not “obsolete,” but the “gray zone” that has persisted for many years is certainly coming to an end.
This article will provide a thorough explanation of the actual situation of account freezing, the legal background, and the three options that traders should take going forward. Especially for beginners who are just starting to trade, we will convey the path with the lowest risk.
✅ What You’ll Learn in This Article
- Why has bank account freezing been rapidly increasing since June 2025?
- The three-layer legal background (Financial Instruments and Exchange Act, revised Payment Services Act, AML/CFT) behind account freezing
- The risks of all four major deposit and withdrawal routes (bank transfers, wallets, cryptocurrencies, credit cards)
- Comparison of the 3 options (domestic FX, prop firms, continuing overseas FX)
- Why beginners should start with prop firms
【Video】The Whole Picture of Overseas FX Regulations and Future Options (Coming Soon)
【Conclusion】Overseas FX is Not “Obsolete” but the “Gray Zone is Ending”
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 “solicitation activities by unregistered business operators,” and there is no law that punishes traders for using overseas FX.
However, the environment where many traders have enjoyed “easy deposit and withdrawal through domestic bank transfers” is certainly coming to an end.


3 Options Going Forward
| Option | Risk | Suitable For |
|---|---|---|
| ① Returning to Domestic FX | Minimum | Stability-oriented, with large self-funds |
| ② Switching to Prop Firms【Recommended】 | Small | Those with skills but little capital, beginners |
| ③ Continuing Overseas FX | Large | Those who understand the risks and want to continue |
Especially for beginners who are just starting to trade, I strongly recommend starting with ② Prop Firms. The reason will be explained in more detail later.
【Reality】Reasons Why Overseas FX Account Freezing Has Been Rapidly Increasing Since June 2025
Since late June 2025, posts containing the keyword “overseas FX account freezing” 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 anxiety such as “Will my account be okay?” and “Will bank transfers no longer be usable?”
Banks with Many Freezing Reports
In particular, the following online banks have seen a noticeable increase in reports of freezing and usage restrictions.
⚠️ Banks with Many Freezing Reports
- GMO Aozora Net Bank: Explicitly prohibits remittances to overseas FX operators
- PayPay Bank: Many reports of usage restrictions for remittances to unregistered operators
- Rakuten Bank: Restricts remittances to operators listed on the Financial Services Agency’s warning list
These online banks were used by many traders due to the ease of account opening and low transfer fees. However, their anti-money laundering measures have also been tightened, and remittances related to overseas FX are more likely to be flagged as “suspicious transactions.”
What Happens When an Account is Frozen
Once an account is frozen, there are the following serious consequences.
- Unable to withdraw funds: If it’s the same account used for salary deposits or utility bill payments, it directly impacts your life
- Takes time to unfreeze: Submission of ID and remittance purpose documents, and the review process can take 2 weeks to 2 months
- Possibility of not being unfrozen: The bank may demand account closure if they determine “continuing the transaction is inappropriate”


【Legal Background】Understanding the “Three-Layer Structure” That Triggers Account Freezing
Account freezing is not caused by a single law. The “three-layer structure” of the Financial Instruments and Exchange Act, the revised Payment Services Act, and the AML/CFT Guidelines is working in a complex way.
Layer 1: Financial Instruments and Exchange Act | Solicitation of Overseas FX is Illegal
At the core of this issue is the Financial Instruments and Exchange Act.
Japanese law clearly states that it is illegal for service providers, regardless of their location, to solicit or provide FX trading services to Japanese residents without being registered with the Financial Services Agency.
The Financial Services Agency has been continuously issuing warnings since 2009 and publishing a list of unregistered operators.
📝 Important Point
What many traders are mistaken about is that “the solicitation by operators is illegal, but there is no law that punishes traders for using it.”
This has been called the “gray zone” situation.
However, this gray zone does not protect traders. The fact that they are participating in an illegal transaction on the counterparty’s side is the root cause of various risks.
Layer 2: Revised Payment Services Act (Enforced in June 2025) | Stricter Regulation of Payment Service Providers
The revised Payment Services Act enforced in June 2025 is the direct trigger for the recent surge in account freezing.
The core of this revision is that it has newly defined “cross-border payment services” as a “foreign exchange transaction,” which was previously in a regulatory gray zone.
Traditionally, payment service providers did not necessarily need a license to operate their business. However, after the revision, the target service providers are now required to register with the Financial Services Agency and comply with strict KYC (customer verification) and AML (anti-money laundering) measures.


It is extremely unlikely that payment service providers, whose core business model is providing services to operators that the Financial Services Agency deems illegal, will be able to obtain a new license.
As a result, many payment service providers will either withdraw or be seen as “suspicious” by the compliance departments of banks.
