扎紧“基于风险”主线 为预防洗钱筑牢屏障

Core Viewpoint - The People's Bank of China, in collaboration with the National Financial Regulatory Administration and the China Securities Regulatory Commission, has drafted the "Management Measures for Customer Due Diligence and Customer Identity Information and Transaction Record Keeping by Financial Institutions (Draft for Comments)" to enhance anti-money laundering efforts and align with international standards [1][2]. Group 1: Regulatory Framework - The draft management measures are a necessary step to implement the Anti-Money Laundering Law and prepare for international assessments [1]. - The revised Anti-Money Laundering Law, effective from January 1, 2024, emphasizes risk-based customer due diligence, requiring financial institutions to tailor their investigations based on customer characteristics and transaction risks [1][2]. - The management measures aim to bridge the gap between China's practices and international standards set by the Financial Action Task Force (FATF), especially ahead of the upcoming international assessment [1][2]. Group 2: Practical Implications - Since the implementation of the Anti-Money Laundering Law in 2007, financial institutions have improved their internal controls and customer due diligence processes, but recent money laundering cases have highlighted deficiencies in these practices [2]. - The management measures stress a risk-based approach, encouraging financial institutions to avoid a one-size-fits-all method and to adapt their due diligence based on the risk profile of clients [2]. - The measures provide a framework that balances legal compliance with practical flexibility, aiming to reduce unnecessary costs while preventing criminal activities [2]. Group 3: Execution and Oversight - The effectiveness of the management measures will depend on financial institutions adopting a proactive risk management approach rather than a checkbox compliance mentality [3]. - Regulatory bodies are urged to enhance risk-based anti-money laundering supervision, ensuring that financial institutions effectively assess, monitor, and mitigate money laundering risks [3]. - A balance must be struck between managing money laundering risks and optimizing financial services to support the healthy development of the financial market [3].