Lexology In-Depth: Anti-money Laundering China EDITION 3
Authors： ZHIYI REN BLAKE WANG
2025 / 11 / 25
In the latest Lexology In-Depth: Anti-money Laundering, our investment management team offers a clear overview of China’s updated anti-money laundering (AML) regime following the major revision of the AML Law in 2024.
The new framework strengthens core requirements, such as:
- mandatory ultimate beneficial-owner (UBO) disclosure
- expanded obligations for designated non-financial sectors
- a stronger risk-based approach to customer due diligence.
Under this new framework, financial institutions must:
- conduct ongoing monitoring
- verify UBO information through national databases
- report large-value and suspicious transactions
- retain customer and transaction data for longer periods.
The law also introduces “special preventive measures” for high-risk individuals, terrorism-related entities, and UN-sanctioned parties, while significantly increasing penalties for AML failures. Cross-border information sharing is tightened under the reciprocity principle, meaning offshore requests require approval from Chinese regulators. Enforcement activity has continued to rise, with China remaining engaged with international bodies such as the Financial Action Task Force (FATF).
Overall, the chapter highlights a maturing AML system that is expanding in scope, becoming stricter, and aligning with global standards. Despite these changes, the AML system continues to emphasize transparency and risk management.
Please click the following link to read the full chapter: https://www.lexology.com/account/activatetempaccess/?sl=nhq2ZgtFCvQrS9uYlHZhZ_DsVY4
