Views: 0 Author: Site Editor Publish Time: 2025-08-29 Origin: Site
On August 4, the People's Bank of China, the State Administration for Financial Supervision and Administration, and the China Securities Regulatory Commission jointly issued the 'Regulations on the Preservation of Customer Due Diligence and Customer Identity Information and Transaction Records of Financial Institutions (Draft for Comments)' to solicit opinions from the public, and the deadline is September 3.
One of the core of the new regulations is: to verify and convey information on a single foreign remittance, and the threshold is clear to 'RMB 5,000 or equivalent US$1,000 or above'. This is also why it pushed 'remittances from domestic to overseas' to the forefront as soon as it appeared.
Unlike the anxiety of the Internet's interpretation of ' whether the foreign exchange is tightened again ', this document is positioned closer to making the underlying requirements of anti-money laundering (AML) into operational rules and is consistent with international standards (FATF'Travel Rules'/R.16). FATF just updated the payment transparency and 'payment information' rules in June this year, emphasizing that cross-border payments must be paid with the real payer/payer information , and introduces finer granular recording and verification requirements for some situations.
Here are the core details:
⚠️ 1. Clarify the trigger threshold for cross-border remittances
The new regulations clearly state that if the funds are transferred to overseas for customers, the amount of a single transaction is RMB 5,000 or a foreign currency equivalent of US$1,000 or above. Financial institutions should verify the identity of the remitter, ensure the information is accurate, and pass key elements to overseas receiving institutions with the money (typically transmitted through the payer/payer field of the SWIFT message ). This not only contains name or name, account number, and residence information; if the remitter has not opened an account at the institution, he or she must also register the document number, contact information and other traceable information.
⚠️ 2. Transfer with the money + traceability
Intermediate banks and collection banks also have 'information integrity' obligations : if the data is missing, it can be supplemented, suspended or even refused to process; if the information is incomplete from abroad, the receiving agency should ask the other party to make up for it. Customer identity information and transaction records shall be kept for at least 10 years. This is the core of 'left traces in the whole chain'.
⚠️ 3. Not all 'large amounts of cash' must be explained firmly'source/purpose'
The new regulations simultaneously set a due diligence threshold of RMB 50,000 or equivalent to US$10,000 for domestic one-time 'counter' financial services (such as cash remittances, cash exchanges, physical precious metals trading, etc.) , but canceled the hard statement of 'individual cash deposits and withdrawals of more than RMB 50,000 in a single transaction of RMB 50,000 or more ' must be registered and changed to risk-oriented (the verification is strengthened only when high risks are strengthened). In other words, it is not the old rumor that '50,000 is said to be used'.
⚠️ 4. The coverage has been significantly expanded, not just the banks
Payment institutions, prepaid card issuers, online micro loans, etc. are clearly included in the AML obligations, and are required to perform KYC, information retention and payment transfer responsibilities. This is consistent with the global integration of 'non-bank payments' into travel rules.
Many people understand '1,000 USD verification + delivery' as lowering the threshold from '10,000 USD'. In fact, it is two different types of 'shadow overlap':
The USD 1,000 threshold comes from the 'payment information' requirement of international payment transparency/travel rules (cross-border payments must bring real payer/payer information for easy traceability), which has been implemented worldwide for a long time; this regulation is to write this matter in detail and thoroughly at the domestic regulatory level.
$10,000 more appears in the context of large-scale suspicious transactions/cash declarations that are familiar to the public, focusing on reporting and monitoring, not technical compliance with 'information is transmitted with the money'. The two will superimpose in reality, but not the same thing. The official media also clearly stated: 'The need to transmit real information for cross-border remittances above US$1,000 is not a new requirement'.
Foreign trade companies pay attention to:
Ensure that the information is true and complete: improve the identity information and account information files of customers and counterparties. Communicate with financial institutions to understand their specific due diligence requirements and information delivery process.
Keep real transaction vouchers: properly preserve contracts, invoices, customs declarations, transportation documents and other supporting materials related to cross-border transactions to ensure that any remittance can clearly and completely correspond to the real trade background.
Plan the remittance rhythm: For frequent small payments, you can communicate with the transaction customers and arrange the payment rhythm reasonably to avoid deliberately splitting the remittance to avoid the threshold, thereby triggering abnormal transaction monitoring.
