21世纪经济报道记者张欣 2026年开春，农业银行与中国银行相继发布公告，分别由行长王志恒、张辉兼任本行首席合规官。此次系两家银行首次设立首 席合规官职位，且均由总行行长亲自兼任，被业内认为"高配"，反映出国有大行对合规内控的重视。 此番高层人事调整，是2024年12月国家金融监督管理总局《金融机构合规管理办法》政策要求下的实质性落地。《合规办法》 明确要求，金融机构应当在机构总部设立首席合规官，且首席合规官应为高级管理人员，并允许行长（总经理）或其他高级管 理人员兼任。该办法自2025年3月1日起正式施行，给予行业一年过渡期。 随着《办法》所设过渡期临近尾声，从国有大行、股份制银行到地方城商行、农商行，各类银行业金融机构正迎来首席合规官 的集中聘任与任命潮。 2025年12月，就有多家银行完成相关人事任命。例如，兴业银行聘任副行长孙雄鹏为首席合规官，平安银行也聘任行长助理吴 雷鸣兼任该职，江阴农商行则由行长倪庆华兼任。去年11月，宁波银行也聘任副行长王勇杰为首席合规官，常熟银行也宣布由 新任行长陆鼎昌兼任这一职务；2026年2月11日晚间，光大银行亦公告称，聘请杨文化为该行副行长兼首席合规官。 （图源：农行 ...

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]

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]

Core Viewpoint - The tightening of regulatory rules and the complexity of the risk environment are driving a restructuring wave in the banking industry's risk and compliance systems [1][7]. Group 1: Appointment Trends - A surge in appointments for Chief Risk Officers (CROs) and Chief Compliance Officers (CCOs) is expected from late 2025 to early 2026, with nearly 10 banks increasing related personnel configurations in the past month [1][7]. - Since the beginning of 2025, over 20 banks and branches have had relevant qualifications approved by regulators [1][7]. - The trend is influenced by the impending expiration of a one-year transition period set by the "Financial Institutions Compliance Management Measures," which requires financial institutions to establish a CCO at their headquarters [1][7]. Group 2: Governance Models - The banking sector exhibits two governance models for CCOs and CROs: "one person holding both positions" and "independent separation" [2][9]. - The "one person holding both positions" model is prevalent, particularly in smaller banks, allowing for unified decision-making in risk and compliance management [2][9]. - Conversely, the "independent separation" model is more common in larger banks, enhancing professional checks and balances within the risk control system [3][10]. Group 3: Talent Acquisition and Challenges - The demand for composite talents is rising, with banks favoring candidates with extensive experience in finance or legal compliance [11][12]. - Some banks are adopting market-based recruitment methods for CCOs, breaking traditional selection models [11]. - Salary levels for CCO positions are increasing, with some banks offering monthly salaries between 100,000 to 130,000 yuan [11]. Group 4: Compliance Management Evolution - Effective compliance management is evolving from a "cost center" to a "value guardian," playing a crucial role in mitigating credit, market, and liquidity risks [12][13]. - The future of compliance governance in the banking industry is expected to become more institutionalized and refined, with clearer responsibilities and a focus on composite compliance talents [12][13]. - The core competencies for CCOs are expected to include deep business insight, precise regulatory interpretation, efficient execution, and strong cross-departmental collaboration [13].

Core Viewpoint - The recent appointment of chief compliance officers (CCOs) in various insurance companies, including China Insurance, reflects a significant shift in the industry towards proactive governance and compliance management in response to regulatory requirements [1][2]. Group 1: Regulatory Changes - The Financial Regulatory Bureau issued the "Compliance Management Measures for Financial Institutions," which will take effect on March 1, 2025, mandating the establishment of CCOs at the headquarters of financial institutions [2][4]. - The CCO is considered a senior management position, directly reporting to the chairman and CEO, and is responsible to the board of directors [2][4]. Group 2: Industry Trends - Multiple insurance companies have recently appointed CCOs, indicating a trend where compliance roles are becoming a focal point in corporate governance [1][2]. - The qualifications for CCOs are stringent, requiring extensive experience in both financial and legal fields, ensuring that appointees possess the necessary expertise [2][5]. Group 3: Implementation Challenges - The establishment of CCOs is not only a response to regulatory demands but also a restructuring of internal governance and risk management systems within insurance companies [4][5]. - Challenges in implementing the CCO role include potential resistance from business departments, the need for clear authority and resource allocation, and the complexity of compliance risks across various operational areas [4][5]. Group 4: Talent Development - There is a notable shortage of qualified professionals who can fulfill the multifaceted requirements of the CCO role, particularly in smaller insurance companies [5][6]. - Recommendations for overcoming these challenges include establishing direct communication between the board and CCOs, integrating compliance performance into executive assessments, and fostering a culture of compliance throughout the organization [5][6].

Core Viewpoint - The recent appointment of compliance officers in various insurance companies, including Bai Feipeng at China Insurance, reflects a response to regulatory requirements and signifies a shift from "passive compliance" to "active governance" in the insurance industry, aiming to strengthen risk management for high-quality development [1][3]. Group 1: Regulatory Changes - The Financial Regulatory Bureau issued the "Compliance Management Measures" which will take effect on March 1, 2025, mandating financial institutions to establish a Chief Compliance Officer (CCO) at their headquarters [3][5]. - The CCO is a senior management position directly reporting to the board and is responsible for compliance management, with a one-year transition period provided for implementation [3][5]. Group 2: Appointment Trends - Several insurance companies have recently appointed CCOs, including Bai Feipeng at China Insurance, Wang Zhu at Guobao Life, and Miao Lianguang at Guohua Xingyi Insurance Asset Management [1][4]. - Some companies have chosen to appoint existing senior management as CCOs, while others have recruited new executives for the role [4]. Group 3: Compliance Management Evolution - The establishment of CCO positions is seen as a restructuring of internal governance and risk management systems within insurance companies [5]. - The CCO role is expected to enhance compliance management by creating a vertical compliance management system, clarifying compliance responsibilities, and embedding compliance throughout business processes [5][6]. Group 4: Challenges in Implementation - Despite the potential benefits, the implementation of the CCO role faces challenges, including resistance from business departments and the need for clear authority and resource allocation [5][6]. - The insurance sector's diverse operations create numerous compliance risk points, complicating the effective coverage of compliance management [5][6]. Group 5: Talent and Development Needs - There is a shortage of qualified professionals who possess the necessary expertise in finance, law, and risk management, particularly in smaller insurance companies [6]. - To address these challenges, insurance companies need to develop a comprehensive approach involving institutional support, talent cultivation, technological empowerment, and cultural integration to ensure the effective implementation of the CCO role [6].

Core Viewpoint - Ping An Bank has appointed Wu Leiming as the Chief Compliance Officer, pending approval from the National Financial Supervision Administration, marking a trend of banks appointing compliance officers in response to regulatory requirements [1][3][12]. Group 1: Appointment Details - Wu Leiming, a veteran of Ping An Bank, has held various key positions since joining the bank during its time as Shenzhen Development Bank [4]. - The appointment of Wu Leiming as Chief Compliance Officer is part of a broader trend, with 12 banks having their compliance officer qualifications approved this year, including Huaxia Bank and Harbin Bank [1][6][8]. Group 2: Regulatory Context - The regulatory framework for compliance officers was strengthened with the release of the "Compliance Management Measures for Financial Institutions" in December last year, which mandates the establishment of Chief Compliance Officer positions at the headquarters of financial institutions [1][12][13]. - The measures emphasize the independence of compliance management and outline the responsibilities of Chief Compliance Officers, including overseeing compliance management systems and reporting to regulatory authorities [13][14]. Group 3: Industry Trends - The trend of appointing compliance officers is characterized by internal promotions or current executives taking on dual roles, reflecting a shift towards more integrated compliance management within banks [8][10]. - Several banks have opted for a diverse appointment model, with some appointing their Chief Compliance Officers from existing senior management, while others are conducting open recruitment for the position [11][12].

Core Viewpoint - The revised "Trust Company Management Measures" will take effect on January 1, 2026, marking the first comprehensive update since its implementation in 2007, aimed at enhancing risk prevention, transformation, and effective regulation of trust companies [1][3]. Group 1: Key Revisions - The revised measures focus on four main areas: emphasizing the core responsibilities of trust companies, strengthening corporate governance, enhancing risk prevention, and reinforcing regulatory requirements [3][4]. - Trust companies are now required to establish a Chief Compliance Officer as per regulatory guidelines, a move that aligns with earlier regulations introduced in March 2023 [6][7]. Group 2: Business Scope Adjustments - The business scope of trust companies has been adjusted to include three main categories: trust business, proprietary asset liability business, and other services [4][11]. - The trust business has been refined to consist of asset service trusts, asset management trusts, and charitable trusts, while proprietary asset liability business now allows for liquidity loans from shareholders and related parties [4][5]. Group 3: Risk Management and Compliance - Trust companies must enhance their risk management frameworks, focusing on compliance and operational risks, and are required to establish a risk reserve management mechanism [10][11]. - The measures prohibit trust companies from promising asset safety or guaranteed minimum returns, and they must ensure that investment products align with investors' risk tolerance [10][11]. Group 4: Governance and Accountability - The revised measures emphasize the importance of corporate governance, requiring independent directors to lead key committees related to audit, nomination, and remuneration [12]. - Trust companies are mandated to manage shareholder behavior and related transactions rigorously, ensuring fair market practices and preventing regulatory arbitrage [12].