The Japanese framework differs in important respects from common law models. Japan codified its law of foreign state immunity comparatively recently, in the Act on the Civil Jurisdiction of Japan with respect to Foreign States (Act No. 24 of 2009) (the ‘Foreign States Act’), which entered into force on 1 April 2010. The Foreign States Act closely follows the United Nations Convention on Jurisdictional Immunities of States and Their Property (2004) (‘UNCJI’), which Japan signed in January 2007 and ratified in 2009. As a consequence, the analysis under Japanese law tends to track the structure and language of UNCJI more faithfully than the common-law statutes (such as the UK State Immunity Act 1978 and Singapore’s State Immunity Act 1979) that pre-date the UNCJI.The concept of state immunity and the absence of an ‘act of state’ doctrineState immunity (or sovereign immunity) prohibits the courts of one state from asserting jurisdiction