中华人民共和国：金融部门评估方案关于反洗钱/打击资助恐怖主义行为的技术说明

IMF Country Report No.25/302 PEOPLE’S REPUBLIC OF CHINA FINANCIAL SECTOR ASSESSMENT PROGRAM November 2025 TECHNICAL NOTE ON ANTI-MONEY LAUNDERING/ This paperonthePeople’s Republic of Chinawas prepared by a staff team of theInternational Monetary Fundas background documentation for the periodic consultation Copies of this report are available to the public from International Monetary Fund•Publication ServicesPO Box 92780•Washington, D.C. 20090Telephone: (202) 623-7430•Fax: (202) 623-7201 International Monetary Fund PEOPLE’S REPUBLIC OFCHINA TECHNICAL NOTE ANTI-MONEY LAUNDERING/COMBATING THE FINANCING This Technical Note was prepared by IMF staff in thecontext of the Financial Sector Assessment Programfor the People’s Republic of China, overseen by theMonetary and Capital Markets Department,International Monetary Fund, and the Finance,Competitiveness & Innovation Global Practice, Prepared ByLegal department,International Monetary Fund CONTENTS Glossary_____________________________________________________________________________________________3 EXECUTIVE SUMMARY____________________________________________________________________________4 AML/CFT LEGAL FRAMEWORK, AND ML/TF RISK AND CONTEXT ____________________________9 SUPERVISORY ML/TF RISK ASSESSMENT FOR BANKS AND PSPS____________________________10 AML/CFT RISK BASED SUPERVISION OF BANKS AND PSP, AND PREVENTIVE MEASURES12 THE IMPACT OF FINANCIAL INTEGRITY ON FINANCIAL STABILITY _________________________15 FIT AND PROPER AND LEGAL PERSONS TRANSPARENCY ____________________________________18 A. Fit and Proper Tests_____________________________________________________________________________18 FINTECH __________________________________________________________________________________________21 FIGURES 1. Short-Term Transmission Channels_____________________________________________________________172. Medium and Longer-Term Transmission Channels_____________________________________________17 TABLES 1. Main Recommendations ________________________________________________________________________72. AML/CFT Enforcement Actions 2021–2023 _____________________________________________________15 Glossary AML/CFTAnti-Money Laundering/Combating the Financing of TerrorismAMLBAnti-Money Laundering BureauFATFFinancial Action Task ForceFSAPFinancial Sector Assessment ProgramMLMoney LaunderingNRANational Risk AssessmentNTNear TermPBCPeople’s Bank of ChinaPEPPolitically Exposed PersonPSNFRANational Financial Regulatory AdministrationPSPPayment Service ProvidersRRMERegulation on the Registration of Market Entities EXECUTIVE SUMMARY According to the recent unpublished domestic national risk assessment (NRA),2China facesrelatively lower ML/TF threats from abroad with a higher risk of domestic criminal proceedsbeing transferred overseas.The update to the NRA concluded that the overall level of ML risk ismedium and has remained the same (since 2017). Notably, there have been some changes in themajor types of illicit proceeds-generating crimes, with tele and internet fraud becoming the mostsignificant ML threat. The domestic understanding of risks including those related to corruption and The amendments to the Anti-Money Laundering Law (AML Law) have been underway since2020, the authorities should prioritize their swift finalization and enactment.The AML/CFTlegal framework has been strengthened through the recent adoption of a series of AML/CFT lawsand regulations. However, the amendments to the AML Law have been underway since 2020 and The authorities have taken positive steps to update the supervisory ML/TF risk assessmentmethodology and the completion of the updated assessment should be expedited. Both banksand payment service providers (PSPs) play key roles, as gatekeepers, of the financial system and arethe main access points for customers. Banks are particularly attractive for criminals to conceal illicitproceeds given their global reach, high levels of activity, and broad range of products/services andcustomers (e.g., PEPs and high net worth individuals). While PSPs are distinct from banks in terms of all entities, in line with a risk-based approach, to ensure that supervisory efforts are directed to the As part of the institutional reform, the Anti-Money Laundering Bureau (AMLB) of the People’sBank of China (PBC) remained responsible for AML/CFT supervision of banks and PSPs.Thereform resulted in a restructuring of provincial branches and the abolition of county branches(established based on administrative regions). In order to sustain efforts and drive more consistent While mechanisms are in place for collaboration between the AMLB and prudentialsupervisors, there is a need for an increased focus on AML/CFT considerations as part of fitand proper assessments.Fit and proper assessments in banks are led by the NFRA and for PSPs areled by the Payments Department within the PBC with contributions from the AMLB. Similar to thearrangement for ban