央行等三部门重磅发布：取消“个人存取现金超5万需登记”规定

Core Viewpoint - The People's Bank of China, along with the National Financial Regulatory Administration and the China Securities Regulatory Commission, has issued new regulations on customer due diligence and transaction record management, effective from January 1, 2026, emphasizing a risk-based approach to financial transactions [1][4]. Group 1: Regulatory Changes - The requirement for banks to register the source of funds for cash withdrawals exceeding 50,000 yuan has been removed, aligning with the previous draft [1][3]. - Financial institutions are mandated to maintain customer identity data and transaction records securely, ensuring they can reproduce each transaction for due diligence and suspicious activity investigations [4][8]. Group 2: Risk-Based Approach - The new regulations advocate for a risk-based customer due diligence process, allowing banks to simplify procedures for low-risk transactions while intensifying scrutiny for high-risk cases [4][8]. - For example, pension withdrawals from clear and stable income sources are considered low risk, requiring only basic identity verification [5][6]. Group 3: Practical Implications - The regulations aim to balance the need for security against the convenience of financial services, allowing banks to adjust their inquiry levels based on the risk profile of transactions [8][14]. - Instances of unusual transaction patterns, such as a sudden influx of large transfers inconsistent with a customer's typical behavior, will trigger enhanced investigations [7][8]. Group 4: Industry Perspectives - Industry experts emphasize the need for clearer rules to navigate the tension between withdrawal freedom and financial security, advocating for collaborative efforts among financial institutions, regulators, and customers [11][14]. - The concept of "withdrawal freedom" is framed as a relative right, subject to compliance with legal and regulatory obligations, particularly concerning anti-money laundering and fraud prevention [12][14].