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Japan FSA Publishes List of 25 Unregistered Crypto Asset Operators: How to Check and What to Do

By:recoin Security Research TeamPublished:Updated:
Japan FSA Publishes List of 25 Unregistered Crypto Asset Operators: How to Check and What to Do

KEY POINTS

  • On October 7, 2026 (UTC), Japan's FSA set up a dedicated page compiling the 25 unregistered crypto asset exchange operators that have received warning letters over the years. Three are domestic and 22 are overseas. PDF and Excel downloads are available.
  • The list is a compilation of past warnings, not a new round of warnings. The page states that the content reflects the situation at the time each warning letter was issued. It does not mean the operators are still active today.
  • Bybit's operating company is listed 3 times. The latest entry is Izakaya Limited (service name IZAKA-YA) in September 2026 (Reiwa 8).
  • Article 63-2 of the Payment Services Act sets the registration requirement, and Article 107 sets the penalties for operating without registration. There is currently no official or expert opinion on whether it is illegal for users themselves to use listed platforms.
  • Not being on the list does not mean a platform is registered. To check a platform, use the FSA's list of registered operators and the JVCEA member list.
  • Now that the list is public, be very careful with anyone who claims they can “recover your funds” or “unfreeze your account” and asks for payment up front or for your seed phrase. You can call the Financial Services Users Helpline at 0570-016811.

Status of verification (as of October 11, 2026)

Confirmed: On October 7, 2026 (UTC), the FSA set up a dedicated page compiling the 25 unregistered operators (3 domestic, 22 overseas) that have received warning letters over the years. It offers PDF and Excel downloads and states that the content reflects the situation at the time of each warning. Not yet confirmed: the full names of all 25 operators and their warning dates (this article lists only those that appear in our sources); the legal effect of the warning letters; whether it is illegal for users themselves to use these platforms; whether the FSA recommends that users withdraw funds; and whether the listed platforms have announced restrictions for Japanese users. All times in this article are UTC unless noted otherwise.

1. What happened: The FSA compiled past warnings into a list of 25 unregistered operators

The short version: the FSA gathered the warning letters it has issued to unregistered operators and published them on one dedicated page. This is a roundup of past warnings. It is not a new round of warnings.

At 8:05 a.m. UTC on October 7, 2026, the FSA's official X account @fsa_JAPAN posted that it had added 「無登録業者との取引は要注意!!~無登録業者との取引は高リスク~」 (Be careful when dealing with unregistered operators; trading with them is high risk) to the alert section on its website's home page. It also published a related page on unregistered crypto asset exchange operators. At 8:06 a.m. UTC, the FSA's alert account @fsa_attention posted the same content.

The dedicated page is titled 「無登録で暗号資産交換業を行う者の名称等について」 (Names of persons conducting crypto asset exchange business without registration). Its URL is https://www.fsa.go.jp/ordinary/chuui/angoushisan_mutouroku.html . The page lists 25 entries, 3 domestic and 22 overseas, with PDF and Excel downloads. The page states that the content reflects the situation at the time each warning letter was issued. It does not mean these operators are still active.

A new page, or an updated list?

Different sources use different wording. The FSA's own post says it “published” (公表) the page. X user @nagoyan400 said the FSA “updated” its warning list. Also, the FSA's 「暗号資産・電子決済手段関係」 (Crypto Assets and Electronic Payment Instruments) policy page already offered PDF and Excel files of unregistered-operator warnings before October 7 (our sources record September 30, 2026). Taken together, we infer that this was more likely a case of putting existing warnings on a new dedicated page. The FSA has not explained this specifically.

Entries confirmed so far

This table lists only entries that appear in our sources. It is not the full list. To see all 25 entries, download the PDF/Excel from the FSA's dedicated page.
Operator / ServiceDomestic / OverseasWhen listedBasis
Izakaya Limited (IZAKA-YA)OverseasSeptember 2026 (Reiwa 8), the latest entry on the listFSA dedicated page; CoinPost
Bybit's operating companyOverseas3 times: May 2021 (Reiwa 3), March 2023 (Reiwa 5), November 2024 (Reiwa 6)The 3 listings appear in multiple sources. The specific months are compiled by X user @Web3uf. Media reports only say “multiple times.”
KuCoin, MEXC, BitgetOverseasRefer to the official PDF/ExcelPer a summary of the dedicated page. Check dates and operating company names against the original for each entry.
BinanceOverseas2018Per a summary of the dedicated page
Bridge Investment and othersDomesticDomestic entries involve 2022 and 2023Per a summary of the dedicated page. Names of the other domestic entries were not collected.

On the media side, CoinPost published a report on X at 9:45 a.m. UTC on October 7, 2026. あたらしい経済 (Atarashii Keizai) published a report at 7:25 a.m. UTC on October 8, 2026. Both match the official page: 25 entries, 3 domestic and 22 overseas.

2. What “unregistered” means: The law and 4 common misconceptions

In short: this list records warnings the FSA has issued to operators. Being on the list does not mean an operator has been judged a scam. Not being on the list does not mean it is registered. Being registered does not mean your principal is protected.

What the law says

Crypto asset exchange service business generally means providing services such as buying, selling, and exchanging crypto assets for users. For the exact definition, refer to the text of the law. According to Japan's Payment Services Act (資金決済に関する法律) as published on e-Gov, Article 63-2 requires registration to conduct crypto asset exchange business for residents of Japan.

Article 107 of the same Act sets penalties for operating without registration. Our sources show a maximum of 3 years and a fine of 3 million yen. For the name of the penalty, please check the current text on e-Gov. After Japan's Penal Code revision in June 2025, “懲役” (imprisonment with labor) was replaced by “拘禁刑” (confinement sentence).

Misconception 1: Being on the list means it is a scam platform

The list compiles warning letters the FSA has issued. The page also states that it reflects the situation at the time of each warning. Our sources contain no FSA finding on whether any operator is involved in fraud. They also contain no explanation of the legal effect of the warning letters.

Misconception 2: Not being on the list means it is registered

The list only includes operators that have received warning letters. X user @Web3uf cautioned that operators not on the list may also be unregistered. According to X user @kitsuasa, he noticed that HTX (formerly Huobi) is not on the list. On October 9, 2026, he asked the FSA why and what criteria it uses. At the time of his post (12:18 p.m. UTC), he had not received a reply. This is a personal account. Our sources do not explain the FSA's criteria.

Misconception 3: Being registered means your money is safe

X user @HIRObg4y pointed out that registration does not guarantee principal or returns. For the official wording, see the original text of the FSA page 「無登録業者との取引は要注意!!」 (https://www.fsa.go.jp/ordinary/chuui/highrisk.html).

Misconception 4: If you used a listed platform, you broke the law

The penalties in our sources apply to the party operating the business without registration. Whether users who use these platforms bear any legal responsibility has not been addressed by the FSA. There is also no commentary from lawyers or other professionals. This article does not draw a conclusion. If you have questions, we suggest contacting the Financial Services Users Helpline (see Section 4).

3. Three steps to check: Is your exchange registered in Japan?

In short: use two official lists to check whether a platform is registered, then use the unregistered-operator list to check whether it has been warned.

  1. Open the FSA's 「暗号資産・電子決済手段関係」 page (https://www.fsa.go.jp/policy/virtual_currency02/), download the list of registered operators (PDF/Excel), and look up the operating company of the platform you use.
  2. Open the 「会員紹介」 (Member Introduction) page on the JVCEA (Japan Virtual and Crypto assets Exchange Association) website (https://jvcea.or.jp/cms/member/) and check whether the company is on the member list.
  3. Compare against the PDF/Excel of the FSA's unregistered-operator list (dedicated page: https://www.fsa.go.jp/ordinary/chuui/angoushisan_mutouroku.html) to see whether it has ever received a warning.

When checking, do not rely on the brand name alone. The operating company name, website domain, and app name should all match. Keep in mind that the list reflects the time of each warning. An operating company may have changed its name or closed since then.

Watch out for fake websites and apps

  • Reach a platform's official website through links on the FSA or JVCEA pages. Do not rely on search ads or links sent by strangers.
  • Check that the operating company named on the website matches the registered list, and that the domain matches the official one.
  • If you are unsure, ask an official help desk first, then decide whether to use the platform.

Our sources do not include an official method for spotting fake websites and apps. The above are only basic checking habits.

4. If your assets are still on a listed platform: Pre-withdrawal checks and where to get help

In short: there is currently no official FSA statement on whether users should withdraw funds or stop using these platforms. You need to decide for yourself whether to move your assets. If you run into trouble, keep your evidence and contact an official help desk.

Some online posts claim that Bybit, IZAKA-YA, and others have announced restrictions for Japanese users. Our sources include neither the original announcements nor links to them, so we cannot confirm this. Please rely on the original announcements from each platform.

If you decide to move your assets: general checks before withdrawing

  • Check the receiving address character by character. After copy and paste, compare at least the first and last few characters.
  • Send a small test amount first. Once it arrives, send the rest.
  • Send to a wallet you control, or to a registered exchange in Japan.
  • A withdrawal never requires your seed phrase or private key. If any page or person asks for them, stop right away.

These are general safe-handling habits, not FSA recommendations. Withdrawal screens and rules differ by platform. Please follow each platform's official instructions.

If you run into trouble: keep evidence and contact an official help desk

First, save your transaction records, screenshots of your account pages, and your messages with the platform. Then contact one of the following help desks.

Check each help desk's official page for current hours.
Help deskPhoneHoursNotes
金融サービス利用者相談室 (Financial Services Users Helpline, FSA)0570-016811Weekdays 10:00 a.m.-5:00 p.m. JST (1:00-8:00 a.m. UTC)Questions about financial services
消費者ホットライン (Consumer Hotline)188Varies by regionConnects you to the nearest consumer affairs center
警察相談専用電話 (Police Consultation Line)#9110Weekdays 8:30 a.m.-5:15 p.m. JST, etc.; varies by prefectureNon-emergency police consultations

One more point. According to X user @kitsuasa, when he previously asked the FSA about HTX, the reply was roughly “It is not a registered operator in Japan, so we cannot respond.” This is one person's experience. It does suggest that official help desks may be limited in what they can do about overseas unregistered platforms.

5. Watch out for “we’ll recover your funds” follow-up scams, and recoin’s view

In short: now that the list is public, be especially careful with anyone who claims they can help you “recover funds” or “unfreeze your account” on these platforms. Our sources do not include any warning from the FSA, the Consumer Affairs Agency, or the National Police Agency about this type of scam. The following is recoin's own advice.

  • Red flag 1: They say they can “recover your funds” or “unfreeze your account” and contact you first.
  • Red flag 2: They ask you to pay a fee, deposit, or “unfreezing fee” up front.
  • Red flag 3: They ask for your seed phrase (a set of words used to restore a wallet), private key, or exchange account password.
  • If something looks suspicious, stop paying and stop sharing information. Then contact the official help desks listed in Section 4.

Legitimate exchanges, wallet services, and government help desks will never ask for your seed phrase or private key.

recoin’s view

We recommend using registered operators in Japan first. Keep your assets in a wallet you control where possible, and back up your seed phrase offline in a safe place.

recoin has on-chain analysis capabilities, but we do not offer fund-tracing services to the public. Whether assets frozen by an exchange or sent to a third party can be recovered depends on the exchange, the stablecoin issuer, and law enforcement. recoin cannot recover frozen funds from an exchange. Be wary of anyone who says they can.

What recoin can help with is when your own wallet will not open: a forgotten password, a wallet.dat file that will not open, a wallet on an old computer or hard drive, double encryption, or only remembering part of a password. If you move your assets from a platform to your own wallet and later run into this kind of problem, you can ask us to assess whether recovery is feasible.

Disclaimer: This article is based on public information as of October 11, 2026. It is not investment or legal advice. It may be updated if the FSA or other parties publish new information.

FAQ

Is Bybit on the FSA’s list of unregistered operators?

Yes. On the list of unregistered crypto asset exchange operators the FSA published on October 7, 2026, Bybit's operating company is listed 3 times. According to X users, the dates are May 2021, March 2023, and November 2024. The list states that its content reflects the situation at the time each warning letter was issued. For details, see the PDF/Excel on the FSA's dedicated page.

How many operators are on the FSA’s unregistered list? Where can I see the full list?

There are 25 entries, 3 domestic and 22 overseas. The full list is on the FSA's dedicated page 「無登録で暗号資産交換業を行う者の名称等について」 (https://www.fsa.go.jp/ordinary/chuui/angoushisan_mutouroku.html), with PDF and Excel downloads.

I used a platform on the list. Did I break the law?

There is currently no explanation from the FSA and no commentary from lawyers. The penalties in Article 107 of the Payment Services Act apply to the party operating without registration. There is no official conclusion on whether users themselves bear any responsibility. If you have questions, you can call the Financial Services Users Helpline at 0570-016811 (weekdays 10:00 a.m.-5:00 p.m. JST).

If a platform is not on the unregistered list, is it safe?

No. The list only includes operators that the FSA has sent warning letters to. Not being on the list does not mean a platform is registered. To check whether a platform is registered, look at the list of registered operators on the FSA's 「暗号資産・電子決済手段関係」 page and the JVCEA 「会員紹介」 page. Then compare the operating company name, URL, and app name. Also note that registration does not guarantee your principal.

Can I still withdraw money from a listed platform? Does the FSA recommend withdrawing?

There is currently no official FSA recommendation on withdrawing funds. We also cannot confirm whether each platform has announced restrictions for Japanese users. If you decide to move your assets, check the address, send a small test amount first, send to a wallet you control or a registered exchange, and never enter your seed phrase or private key. If you run into trouble, you can contact 0570-016811, 188, or #9110.

Someone says they can recover my frozen funds from an exchange. Can I trust them?

Be very careful. Asking for payment up front or for your seed phrase or private key are common red flags. Whether frozen assets, or assets sent to a third party, can be recovered depends on the exchange, the stablecoin issuer, and law enforcement. Legitimate organizations never ask for your seed phrase or private key. If in doubt, contact an official help desk first.

Sources

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