1. 股权结构与信息披露：透明度是关键 纳斯达克要求上市公司充分披露外国股东的信息，确保投资者了解公司股权分布及潜在利益冲突。具体包括： 2. 锁定期（Lock-up Period）：限制短期抛售 纳斯达克要求主要股东（包括外国股东）在IPO后遵守6个月的锁定期（部分情况可延长至12个月），期间不得出售或转让所持 股份。锁定期的目的是稳定股价，防止大股东短期内抛售导致市场波动。 3. 合规性：反洗钱（AML）与外汇管制 外国个人投资者； 外国机构投资者（如主权财富基金、 pension funds、对冲基金、商业银行）； 外国政府或其下属机构； 境外注册的公司（如离岸群岛公司）。 纳斯达克IPO对外国股东的要求，主要体现在股权透明度、合规性、锁定期及信息披露等方面，核心是确保美国资本市场对股东 结构的信任，同时符合美国证券法规（如《1933年证券法》《1934年证券交易法》）及纳斯达克的上市规则。以下是重点要求 的梳理： 一、外国股东的定义与分类 纳斯达克将"外国股东"定义为非美国居民或非美国注册实体的股东，包括： 二、核心要求重点 5. 控制权变更：外国股东出售的影响 若外国控股股东（持股≥50%）出售大量 ...

Core Viewpoint - Effective and efficient Customer Due Diligence (CDD) is an essential component of risk management strategies, helping organizations understand customer identities and clarify business partners [1][2]. Summary by Sections What is Customer Due Diligence (CDD) and Its Importance - CDD involves verifying customer data to understand potential risks associated with new or existing clients, significantly reducing the risk of fraud and financial crimes [2]. - Effective CDD should be rigorous and in-depth, going beyond basic checks to create a comprehensive profile of each customer while ensuring a seamless service experience [2]. Common Challenges - Organizations face several common challenges in implementing CDD processes, including: - **Data Challenges**: Incomplete or distorted customer information can hinder thorough CDD [4]. - **Technical Shortcomings**: Manual processes are time-consuming and prone to errors, making timely CDD completion difficult without appropriate technological support [5]. - **Resource Limitations**: Budget and human resource constraints put pressure on compliance teams to efficiently conduct CDD [6]. - **Complex Regulatory Environment**: Keeping up with evolving regulatory requirements adds complexity to CDD processes [7]. Customer Due Diligence Checklist - A checklist is provided to help build an accurate and efficient CDD framework, covering key elements such as: - **Screening**: Identifying potential financial crime threats and ensuring compliance with global regulations [8]. - **Enhanced Due Diligence (EDD)**: Necessary when risks are detected, providing critical information about high-risk business relationships [9]. - **Identity Verification**: Essential for reducing fraud risk and establishing brand trust by verifying the true identity of clients [10]. - **Ongoing Monitoring**: CDD is a continuous process, requiring regular reports to identify suspicious activities and adapt to changing risks [11].

Core Viewpoint - The Federal Reserve's decision to revoke the 2022 regulatory guidance on banks' cryptocurrency and dollar token operations marks the end of the Biden administration's stringent regulatory policies, signaling a turning point for the U.S. cryptocurrency market towards relaxed banking services [1][6]. Group 1: Regulatory Changes - The "Choke Point 2.0" initiative began in 2022, requiring banks to report before engaging in cryptocurrency operations, effectively raising the industry's entry barriers [3]. - In 2023, major regulatory bodies further tightened controls by defining decentralized network assets as "inconsistent with banking safety standards" and introducing a "no objection" licensing process, granting regulators veto power [3]. - The tightening of policies was triggered by the systemic risk concerns following the collapse of the FTX exchange in 2022, leading regulators to attempt to isolate the cryptocurrency market by cutting off banks' funding channels [3]. Group 2: Impact of Policy Reversal - With the anticipated return of Trump in 2025, there has been a significant shift in cryptocurrency regulation, including new rules from the OCC allowing national banks to provide cryptocurrency custody and stablecoin reserve management without prior approval [5]. - The Federal Reserve's recent announcement to eliminate the reporting requirements for banks engaging in cryptocurrency business signifies the end of a three-year period of high-pressure regulation, reducing compliance barriers and legal risks [6]. - The policy shift is expected to enable banks to resume cryptocurrency services, improving fiat liquidity and accelerating the use of stablecoins in cross-border payments and DeFi applications [6][8]. Group 3: Future Outlook - The recent regulatory relaxations, combined with favorable actions from the Trump administration, such as SEC approval of altcoin ETFs and the appointment of pro-crypto officials, may lead to significant traditional capital inflows into the cryptocurrency market [8]. - Analysts predict that improved liquidity and regulatory transparency could drive Bitcoin to surpass historical highs, entering a "compliance development 2.0 phase" [8]. - Despite the positive signals from policy relaxations, the industry will still face challenges related to anti-money laundering (AML) and consumer protection, with future regulations likely focusing on "risk-based management" rather than blanket restrictions [8].

Investment Rating - The report does not explicitly provide an investment rating for the industry Core Insights - The dynamic nature of financial crime remains a significant issue for financial institutions in the Asia-Pacific (APAC) region, driven by innovative methods employed by criminals and increasing regulatory demands [3] - Financial institutions must ensure the effectiveness of their anti-money laundering (AML) programs while balancing customer experience, effectiveness, and efficiency [4] - The evolution of global regulatory frameworks will continue in 2025, driven by the need for financial institutions to have a deeper understanding of their clients and to adopt advanced automated financial crime risk management technologies [5] Regulatory Focus - Strengthening beneficial ownership transparency is a key focus for regulators, especially in Southeast Asia, following high-profile money laundering scandals [6] - There is an increasing emphasis on risk-based approaches, requiring financial institutions to adopt effective risk management strategies tailored to specific risks [6] - The application of advanced automated financial crime risk management technologies, including AI, must meet regulatory expectations and ethical standards [7] Emerging Financial Crime Methods - By 2025, new financial crime methods are expected to emerge, highlighting the need for financial institutions to update and strengthen their risk management procedures [8] - Criminals are increasingly using synthetic identity fraud, combining real and fake information to create new identities, necessitating effective control measures from financial institutions [9] - Online gaming platforms are being exploited for money laundering due to the ease of converting in-game currency to real money, requiring financial institutions to reassess their risk management strategies [10] - Digital assets and cryptocurrencies are becoming a regulatory focus, with institutions needing to understand the regulatory landscape and implement anti-money laundering checks [11] Geopolitical Influences - Geopolitical tensions surrounding Russia, China, and the Middle East will continue to impact compliance in the APAC region, complicating international sanctions regimes [13] Embracing Technology - Financial institutions need to evolve their anti-financial crime (AFC) operations by leveraging artificial intelligence and technology to enhance compliance and risk management [14] - A balanced approach between automation and human expertise is essential for effective risk management, with a clear strategy for AI implementation being crucial [15] - AFC executives should prioritize strengthening their technology, processes, and operational models to improve compliance and risk management [17]