安永_中国大陆和香港的金融业内部审计监管政策和活动——2025年第三季度

23 October 2025 In Q3 2025, financial regulatory supervision continued to open up financial markets, while strengthening industrysupervision and penalties. As a core department of financial institutions, internal audit should consistently monitor This article aims to provide insights and highlights on regulatory requirements and areas of focus related to internal audits inthe financial industry across the Chinese mainland and Hong Kong. It also covers the activities of international and Chinese 1. Chinese mainland financial industry regulations In Q3 2025, the National Financial Regulatory Administration (NFRA), People’s Bank of China (PBOC), China SecuritiesRegulatory Commission (CSRC), China Trustee Association and other organizations have issued new regulations or self-regulatory rules for local asset management companies, securities and subsidiaries, trust companies, futures companies, Key regulations related to internal audit, as well as areas that internal audit teams should focus on in the Chinese mainland Suitability management of products by financial institutions ▪In July, to regulate the suitability management of products by financial institutions and to protect the lawful rights andinterests of financial consumers, NFRA issued theMeasures for the Suitability Management of Products by FinancialInstitutions.The Measures clarify the scope and responsibilities for product suitability management in financial Trust company management, culture development and green trust Culture development: ▪In July, to promote high-quality development of the trust industry, the China Trustee Association issued theGuidelinefor trust culture development in trust companies,to further align with the leading practices of compliance culturedevelopment in the financial markets of Europe, the United States and Hong Kong. The Guideline requires trust Green Trust: ▪In July, to guide trust companies in developing green trusts, the China Trustee Association issued the Green TrustGuideline. The Guideline requires the trust companies to include the review of implementation of green trust business ▪Meanwhile, the China Trustee Association released theEnvironmental, Social and Governance (ESG) DisclosureGuideline for Trust Industry,which requires trust companies to disclose the adopted policies, measures andperformance in areas such as corporate governance framework, ESG governance, trust culture development, internal Trust company management: ▪In September, NFRA issued theAdministrative Measures for Trust Companies, which regulate the business operationsof trust companies, strengthen management of financial consumer protection, shareholder behavior, related-partytransactions and salary incentives, stipulate prohibited behaviors in trust business operations, and enhance internalcontrols and risk management. Specifically, the Measures explicitly require that trust companies to:-conduct departure audit for directors and senior management personnel who are to resign and report the auditresults to the institution appointed by NFRA.-establish and improve the internal audit framework, independently and objectively review, evaluate and facilitatethe improvement of the company's business operation, risk management, internal control and corporate -regarding the sale of asset management trust products, promotion of asset service trusts and charitable trusts,establish and improve management systems covering personnel, materials, agency, customer information Local asset management company ▪In July, NFRA issued theInterim Measures for the Supervision and Regulation of Local Asset Management Companiestostrengthen the supervision and administration of local asset management companies, standardize business operations,enhance risk management and clarify the regulatory requirements on concentration risk. Specifically, the Measures Classification rating for non-bank payment institutions ▪In July, the People's Bank of China solicited public opinions on theAdministrative Measures for the Classification andRating of Non-Bank Payment Institutions (Revised Draft for Public Comment), to further improve differentiatedsupervision and rationally allocate regulatory resources. The revised content mainly involves adjusting and refining the Securities alternative investment and private fund subsidiaries management ▪In July, CSRC issued theSelf-Regulatory Rules Application Opinion No. 8–application opinion on relevant provisions ofthe 'Management Specifications for Alternative Investment Subsidiaries of Securities Companies' and the' ManagementSpecifications for Private Fund Subsidiaries of Securities Companies’, to facilitate thecompliant operation of the two Anti-money laundering (AML) ▪In August, to implement the new AML Law, PBOC, NFRA and CSRC issued theAdministrative Measures for CustomerDue Diligence Investigations and the Retention of Customer Identity Information and Transaction Records by FinancialInstitutions (Draft for Comment)t