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 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].