（原标题：取消一刀切式操作，也应适用于金融反诈） 2025年11月28日，中国人民银行、国家金融监督管理总局、中国证监会联合公布了《金融机构客户尽职 调查和客户身份资料及交易记录保存管理办法》，自2026年1月1日起施行。新规中，最受关注的莫过于 取消"个人存取现金超5万元需登记资金来源或用途"的规定，这与此前征求意见稿的表述一致。 新的管理办法取消登记要求，正是对风险防控和服务便利之间平衡的重新校准。新的管理办法提出，根 据客户特征和交易活动的性质、风险状况采取相应的尽职调查措施——对于低风险情形，采取简化措 施；对于高风险情形，采取强化措施。这体现了反洗钱监管的"风险为本"原则，需要金融机构改变过去 的一刀切方式。 这意味着金融机构的风控模式必须实现大升级，不再简单以交易金额作为触发条件，而是综合考量客户 身份特征、交易行为模式、账户历史表现等多维度信息，构建动态风险画像。这种基于真实风险水平的 差异化处置，才是真正有效的风控。这种以风险为本的理念也应适用于金融反诈工作中。 科技赋能为实现这种精准风控提供了有力支撑。当前，人工智能、大数据等技术已能够对海量交易数据 进行智能分析，通过机器学习算法识别异常模 ...

Core Viewpoint - The new regulation by Chinese financial authorities aims to shift from a rigid "one-size-fits-all" approach to a more risk-based management model, enhancing service efficiency while maintaining effective monitoring of high-risk transactions [1][2]. Group 1: Policy Changes - The new rule eliminates the mandatory requirement for individuals to register the source of funds when withdrawing or depositing cash exceeding 50,000 yuan, reflecting a significant shift in financial regulation [1]. - This change is expected to reduce operational costs for financial institutions and alleviate inconveniences for the public, aligning with global trends in anti-money laundering regulations [1][2]. Group 2: Implementation and Impact - Financial institutions will adopt a risk-based principle for due diligence, allowing normal financial activities to proceed without excessive inquiries, while focusing on monitoring suspicious transactions more effectively [2]. - The regulation is set to take effect on January 1, providing financial institutions with adequate time to prepare for the transition, ensuring a smooth implementation of the new policy [3].

Core Viewpoint - The People's Bank of China emphasizes the importance of improving the legal system and financial regulatory framework, highlighting a shift from "rule-based" to "risk-based" anti-money laundering regulations [1] Group 1: Legal and Regulatory Framework - The People's Bank of China is working on enhancing the legal system and financial regulatory framework, indicating a progressive approach to governance [1] - There is a focus on improving anti-money laundering regulations, transitioning from a "rule-based" to a "risk-based" approach [1] - The bank aims to strengthen the institutional framework in the payment sector to better protect users' legitimate rights and interests [1] Group 2: Credit Management and Administrative Procedures - The implementation of the "Credit Industry Management Regulations" is underway, with plans to develop detailed management methods and complaint handling procedures [1] - The People's Bank of China is compiling a list of responsibilities and administrative licensing guidelines to clarify boundaries and establish clear approval standards and processes [1] - This initiative aims to solidify the institutional guarantees for lawful performance of duties [1]

Core Viewpoint - The People's Bank of China emphasizes the importance of enhancing the legal framework and financial regulatory system, transitioning from a "rules-based" to a "risk-based" approach in anti-money laundering regulations [1] Group 1: Legal and Regulatory Framework - The People's Bank of China is working on improving the legal system to ensure better financial regulation [1] - There is a focus on enhancing the anti-money laundering regulations, shifting towards a risk-based approach [1] - The bank aims to strengthen the institutional framework in the payment sector to protect users' legitimate rights and interests [1] Group 2: Credit Management and Administrative Procedures - The implementation of the Credit Industry Management Regulations is underway, with plans to develop detailed management methods and complaint handling procedures [1] - The People's Bank of China is compiling a list of responsibilities and administrative licensing guidelines to clarify boundaries and standards for approval processes [1] - This initiative aims to solidify the institutional guarantees for lawful performance of duties [1]

Core Viewpoint - China should seize the opportunity of the new round of FATF evaluations to continuously enhance its anti-money laundering (AML) standards and risk prevention capabilities, pushing for a comprehensive alignment of its AML work with international standards, and transitioning to a "risk-based" management approach in AML regulation [1][15]. Regulatory Changes - The People's Bank of China, the National Financial Regulatory Administration, and the China Securities Regulatory Commission jointly released a draft for public consultation on the management of customer due diligence and transaction record-keeping for financial institutions, which proposes significant adjustments to previous regulations [2][5]. - The draft removes the requirement for banks to verify the identity of customers making cash deposits or withdrawals exceeding 50,000 RMB, which had previously caused discomfort among customers [2][6]. Training and Implementation - Financial institutions are initiating new rounds of training focused on identifying high-risk scenarios and strengthening AML due diligence, despite the relaxation of certain regulations [3][5]. - The implementation of the draft will lead to a more refined AML management approach, emphasizing continuous customer due diligence and enhancing the transparency of beneficial ownership [12][15]. Enhanced AML Measures - The draft introduces several targeted AML measures, including prohibiting simplified due diligence in high-risk scenarios, monitoring specific sensitive groups, and controlling associations with high-risk regions [4][12]. - Financial institutions are required to establish mechanisms to stay updated on high-risk countries and regions, ensuring that enhanced due diligence measures are applied to transactions from these areas [4][14]. International Alignment - The release of the draft signifies a step towards aligning China's AML risk management with international standards, particularly in preparation for the upcoming FATF evaluation [13][15]. - Following the FATF's previous evaluations, experts suggest that China should actively improve its AML laws and practices to meet international expectations and enhance its financial stability [14][15].

Core Viewpoint - The article discusses the transition of anti-money laundering (AML) efforts in China from a "rule-based" approach to a "risk-based" approach, emphasizing the need for financial institutions to adapt to the complexities of modern financial transactions [1][4]. Summary by Sections - The new draft of the "Management Measures for Customer Due Diligence and Customer Identity Information and Transaction Record Keeping" removes the requirement for banks to verify the source or purpose of cash deposits or withdrawals exceeding 50,000 RMB, which was a contentious rule in the previous version [2][3]. - The updated measures specify that while cash deposits do not require due diligence, other financial services such as account openings, cash remittances, and precious metal transactions exceeding 50,000 RMB or equivalent to 10,000 USD will still necessitate customer due diligence [3][5]. - The shift to a "risk-based" approach is highlighted, where financial institutions are encouraged to assess the risks associated with different services and clients, allowing for differentiated AML measures [3][4]. - The new draft also introduces simplified measures for low-risk clients and outlines enhanced due diligence for high-risk users, moving away from a one-size-fits-all approach [5]. - The launch of the new draft signifies China's ongoing efforts to align its AML framework with international standards, particularly in light of the upcoming fifth round of international mutual evaluations by the Financial Action Task Force (FATF) [6].

Core Viewpoint - The People's Bank of China, along with other regulatory bodies, has released a draft regulation aimed at improving customer due diligence and transaction record-keeping for financial institutions, which notably removes the requirement for individuals to disclose the source or purpose of cash transactions exceeding 50,000 RMB, indicating a shift towards a risk-based regulatory approach [1][2][4]. Group 1: Regulatory Changes - The new regulation provides clear operational guidelines for financial institutions regarding customer due diligence, identity verification, and transaction record retention [2]. - The removal of the previous requirement for cash transactions over 50,000 RMB or equivalent in foreign currency to disclose the source or purpose is a significant change aimed at enhancing customer experience and operational efficiency [2][3]. - The regulation mandates that financial institutions conduct due diligence for cash transactions exceeding 50,000 RMB or equivalent in foreign currency, ensuring proper identification and documentation of customers [3]. Group 2: Impact on Financial Institutions - The regulation encourages financial institutions to transition from passive compliance to proactive risk management, necessitating the development of a customer risk grading system [3][5]. - Financial institutions are expected to leverage technology to optimize service processes for low-risk customers while implementing enhanced due diligence for high-risk clients [3][5]. - The introduction of this regulation is part of a broader effort to strengthen anti-money laundering measures and improve the effectiveness of due diligence practices across various financial sectors [4]. Group 3: Broader Context and Implications - The regulation aligns with the Anti-Money Laundering Law of the People's Republic of China and aims to meet international assessment requirements for anti-money laundering [4]. - The recent surge in anti-money laundering policies reflects a commitment to refining the regulatory framework and enhancing risk management capabilities within financial institutions [4]. - The comprehensive approach to risk prevention across different sectors, including finance and precious metals, is expected to bolster the overall stability and sustainability of the financial market [4].

Core Viewpoint - The recent draft regulation by Chinese financial authorities aims to balance risk prevention and customer service optimization, moving away from rigid requirements to a more nuanced approach in anti-money laundering efforts [1][2][3] Group 1: Regulatory Changes - The draft regulation cancels the previous requirement for banks to verify the source of funds for cash transactions over 50,000 yuan, which was a contentious point in the 2022 rules [1][2] - The new approach focuses on comprehensive due diligence for high-risk transactions, such as cash remittances and physical precious metal trades exceeding 50,000 yuan [1][3] Group 2: Risk Management Strategy - The shift from a simple threshold-based management to a risk-based approach emphasizes the need for financial institutions to implement tiered management strategies, simplifying processes for low-risk scenarios while intensifying scrutiny for high-risk cases [3] - Financial institutions are encouraged to leverage technology to enhance service efficiency, such as notifying customers in advance about required documentation and improving services for vulnerable populations [3] Group 3: Customer Experience - The draft regulation reflects a response to public demand for more convenient banking services, highlighting the importance of respecting customer needs to drive service optimization [2][3] - The integration of intelligent risk control systems with human oversight is suggested to minimize errors while ensuring compliance, such as marking regular withdrawals by retirees as low risk [3]

Core Viewpoint - The recent adjustments to anti-money laundering regulations in China signify a shift towards a more risk-based and nuanced approach, moving away from rigid thresholds in customer due diligence [2][3][4] Summary by Relevant Sections Regulatory Changes - The People's Bank of China, the National Financial Regulatory Administration, and the China Securities Regulatory Commission have jointly released a draft for public consultation regarding customer due diligence and transaction record management [1][2] - A significant change in the draft is the removal of the requirement for individuals to declare the source or purpose of cash transactions exceeding 50,000 yuan, indicating a transition to a more refined regulatory framework [2][3] Risk-Based Approach - The draft emphasizes a "risk-based" principle for customer due diligence, requiring financial institutions to tailor their investigation measures based on customer characteristics and transaction risks, avoiding a one-size-fits-all approach [3][4] - Low-risk scenarios will see simplified investigation processes, while high-risk situations will necessitate more stringent due diligence measures [4][7] Focus on High-Risk Areas - The draft increases the focus on high-risk scenarios, explicitly stating that simplified due diligence cannot be applied when there are suspicions of money laundering or terrorist financing [7] - Financial institutions are required to monitor specific high-risk groups and regions, ensuring that enhanced due diligence is applied to transactions involving clients from high-risk countries or those associated with high-risk individuals [7] Public Consultation and Future Implementation - The public consultation period for the draft will last until September 3, with expectations that the finalized regulations will be implemented before the FATF's fifth round of mutual evaluations [7]

Core Viewpoint - The recent adjustments to anti-money laundering regulations by financial institutions in China aim to simplify cash withdrawal processes while maintaining a focus on high-risk transactions and clients [4][8][16]. Group 1: Regulatory Changes - The new draft regulation allows cash withdrawals over 50,000 yuan without the need to explain the source or purpose of the funds, a significant change from the previous requirement [4][12]. - Financial institutions are still required to conduct due diligence for single transactions exceeding 50,000 yuan in cash remittances and physical precious metal transactions [5][8]. Group 2: Risk-Based Approach - The draft regulation emphasizes a "risk-based" principle for customer due diligence, allowing simplified measures for low-risk clients while enforcing stricter scrutiny for high-risk clients [8][16]. - Specific measures include prohibiting simplified due diligence in cases where there are suspicions of money laundering or terrorist financing [16]. Group 3: Historical Context - The previous regulation, implemented in 2022, faced public backlash due to concerns over privacy and operational complexity, leading to its postponement [11][12]. - The new draft reflects a balance between enhancing anti-money laundering efforts and protecting individual financial activities and privacy [9][16].