关于印发《会计师事务所反洗钱工作管理办法》的通知财会〔2025〕20号

Core Viewpoint - The article outlines the "Management Measures for Anti-Money Laundering Work of Accounting Firms," which aims to strengthen and standardize the anti-money laundering obligations of accounting firms in accordance with the Anti-Money Laundering Law of the People's Republic of China [2][3]. Group 1: General Principles - The measures are established based on the Anti-Money Laundering Law and are applicable to accounting firms legally established within the territory of China [3]. - The State Council's financial department is responsible for the national supervision and management of accounting firms' anti-money laundering efforts, while provincial financial departments oversee local compliance [3]. Group 2: Anti-Money Laundering Obligations - Accounting firms must establish internal control systems for anti-money laundering that align with their risk profiles, including risk assessments, customer due diligence, and suspicious transaction reporting [4]. - Firms are required to regularly identify and assess money laundering risks and implement appropriate risk management measures based on these assessments [5]. - Customer due diligence must be completed before establishing business relationships, with firms allowed to finalize this within a reasonable timeframe before the conclusion of the entrusted matter [6]. Group 3: Customer Due Diligence - Firms must take reasonable measures to verify customer identities and understand the ownership and control structures of non-natural person clients [5][6]. - Continuous monitoring of customer relationships is mandated, with firms required to reassess customer risk profiles regularly [8]. - Enhanced due diligence measures must be applied to high-risk clients, including those from high-risk countries or involved in suspicious activities [10]. Group 4: Reporting and Record Keeping - Accounting firms must submit suspicious transaction reports if they suspect money laundering activities, regardless of the amount involved [16]. - Firms are required to maintain customer identity information and business records for at least ten years after the termination of the business relationship [20]. - Continuous training on anti-money laundering practices is necessary for firm personnel to ensure compliance and awareness [22]. Group 5: Supervision and Management - Provincial financial departments are tasked with supervising and inspecting the compliance of accounting firms with anti-money laundering obligations [23]. - The Chinese Institute of Certified Public Accountants is responsible for self-regulation within the industry, including the development of guidelines and the assessment of money laundering risks [24]. Group 6: Legal Responsibilities - Violations of the anti-money laundering law and the established measures can result in penalties as outlined in the law, with criminal liability for serious offenses [27][28].