Financial Institutions' Customer Due Diligence and Record-Keeping Measures Announced, Effective January 1, 2026

Deep News
Nov 28

The People's Bank of China (PBOC), the National Financial Regulatory Administration (NFRA), and the China Securities Regulatory Commission (CSRC) have jointly issued Order No. 11 of 2025, titled "Measures for the Administration of Customer Due Diligence and the Preservation of Customer Identity Information and Transaction Records by Financial Institutions."

The Measures, approved at the 14th executive meeting of the PBOC on October 11, 2025, and endorsed by the NFRA and CSRC, will take effect on January 1, 2026. The document was signed by PBOC Governor Pan Gongsheng, NFRA Chairman Li Yunze, and CSRC Chairman Wu Qing on October 31, 2025.

Key provisions include:

1. Scope of Application: The Measures apply to: - Policy banks, commercial banks, rural cooperative banks, rural credit cooperatives, and village banks - Securities firms, futures companies, and securities investment fund management companies - Insurance companies and insurance asset management firms - Trust companies, financial asset management firms, corporate group finance companies, financial leasing companies, auto finance firms, consumer finance companies, money brokerage firms, and wealth management companies - Non-bank payment institutions - Other financial institutions designated by the PBOC

2. Core Requirements: - Financial institutions must implement risk-based customer due diligence (CDD), including identifying beneficial owners and applying enhanced or simplified measures based on risk levels. - Customer identity information and transaction records must be securely preserved for at least 10 years after business relationships end or transactions conclude. - Institutions must establish internal control systems for CDD and record-keeping, with regular audits and assessments.

3. Special Provisions: - Enhanced due diligence is required for high-risk customers, including politically exposed persons (PEPs). - Simplified measures may apply to low-risk scenarios, such as transactions with government entities or listed companies. - Cross-border transactions face additional scrutiny, with specific requirements for remittance information.

4. Implementation Timeline: - Existing customer relationships must be reviewed within six months (high-risk customers) or two years (all customers) of the Measures taking effect. - Previous regulations on customer identification and record-keeping (2007 and 2022 versions) will be repealed upon implementation.

The Measures aim to combat money laundering and terrorist financing while maintaining financial security and order. Digital RMB-related CDD and record-keeping will follow separate regulations.

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