过渡期收官在即，银行业首席合规官密集就位， 如何推进从“被动遵循”到“主动治理”？

Core Insights - The banking industry is undergoing a restructuring wave in risk and compliance systems due to tightening regulatory rules and a complex risk environment [1] - A surge in appointments of Chief Risk Officers (CROs) and Chief Compliance Officers (CCOs) is expected by the end of 2025 and early 2026, with over 20 banks and branches already approved for related positions since early 2025 [1] - The implementation of the "Compliance Management Measures for Financial Institutions" mandates the establishment of CCOs at the headquarters level, who will be senior management personnel directly reporting to the board [1] Group 1: Appointment Trends - Nearly 10 banks have intensified their hiring for compliance roles in the past month, with institutions like Ping An Bank and Minsheng Bank announcing relevant appointments [1] - The first approved CCO in the banking sector post-implementation of the new measures is Yang Hong from Huaxia Bank, while Zhou Wei from Shixing Dazhong Village Bank is the first CCO for a rural bank [2] Group 2: Governance Models - Two governance models are emerging: "one person holding multiple roles" and "independent separation" for CCOs and CROs [2][3] - The "one person holding multiple roles" model is prevalent among smaller banks, allowing for unified decision-making in risk and compliance management [3] - The "independent separation" model is more suitable for larger banks, enhancing professional checks and balances within risk management and compliance [3] Group 3: Talent and Recruitment - The establishment of CCO and CRO positions presents new challenges in talent acquisition, with a preference for candidates possessing a combination of frontline business experience, cross-regional vision, and professional qualifications [4] - Some banks are adopting market-based recruitment strategies for CCOs, requiring candidates to have over eight years of experience in finance or legal compliance [5] - Salary levels for CCO positions are rising, with some banks offering monthly salaries between 100,000 to 130,000 yuan [5] Group 4: Compliance Management Evolution - The number and amount of penalties in the banking sector remain high, with 6,521 penalties totaling 2.641 billion yuan in 2025, a 44.95% increase from 2024 [5] - Effective compliance management is evolving from a "cost center" to a "value protection center," crucial for mitigating credit, market, and liquidity risks [5] - Future compliance governance is expected to become more institutionalized and refined, with a focus on clear responsibilities and the need for composite compliance talents [6] Group 5: Role of Chief Compliance Officers - The role of CCOs is pivotal in the compliance system, requiring capabilities in business insight, regulatory interpretation, execution, and cross-departmental collaboration [6] - As the transition period for CCO appointments concludes, the emphasis will be on ensuring these compliance leaders effectively facilitate a shift from passive regulatory adherence to proactive compliance governance [6]