Japan: Implemented UK-Japan CEPA including cross-border data transfer regulation measures

On 1 January 2021, the Agreement for a Comprehensive Economic Partnership between Japan and the UK (CEPA) entered into force. Article 8.84 forbids the parties to restrict the cross-border transfer of information by electronic means. Nevertheless, a party is allowed to do so to achieve a "legitimate public policy objective" if such a measure does not constitute an arbitrary or unjustifiable discrimination or restriction on trade. Moreover, this Article does not apply to government procurement and information processed by or on behalf of a Party.