银行治理结构20年大变革：首席合规官接棒监事会，“硬制衡”取代“软监督”

Core Viewpoint - The governance structure of Chinese commercial banks, which has been in place for over 20 years, is undergoing significant changes as the supervisory board is being replaced by Chief Compliance Officers (CCOs) in response to regulatory requirements [3][32][57] Group 1: Regulatory Changes - The "Compliance Management Measures for Financial Institutions" was released on December 25, 2024, mandating the establishment of CCO positions at financial institutions [4][32] - By March 1, 2025, all financial institutions must complete the appointment of CCOs and related compliance structures, marking the end of the supervisory board's role [4][32] - As of early 2026, at least 56 financial institutions have had their CCO qualifications approved by regulators, with over 20 banks and branches already in compliance [3][6][35] Group 2: Transition from Supervisory Board to CCO - The supervisory board, which has been in place for over 20 years, is officially being phased out, leaving only the board of shareholders and the board of directors [3][32] - The transition signifies a shift from "soft supervision" to "hard checks and balances" within the governance framework of Chinese commercial banks [3][32][57] - The responsibilities of the supervisory board will now be taken over by the CCO, who will have enhanced authority and independence [4][32] Group 3: CCO Responsibilities and Powers - CCOs are tasked with compliance risk monitoring, internal audits, and ensuring compliance with new products and business strategies [4][32] - The CCOs will have significant independence, with the authority to access all internal documents and data necessary for compliance assessments [21][25] - CCOs will also have the power to halt operations on projects that pose compliance risks and will be involved in the performance evaluations of business line leaders [23][25] Group 4: Historical Context and Need for Change - The effectiveness of the supervisory board has been questioned, as it has not met the expectations of policymakers regarding compliance oversight [8][39] - Regulatory scrutiny has intensified since 2018, with a shift in focus from growth to compliance, leading to increased penalties for violations [10][39] - The transition to CCOs is seen as a necessary evolution to address the shortcomings of the previous governance structure [8][39][48]