The signal of "zero tolerance" in private fund regulation has been released once again. On January 23, the China Securities Regulatory Commission (CSRC) imposed administrative penalties on Zhejiang Ruifengda Asset Management Co., Ltd. (Ruifengda), its actual controller Sun Wei, and five affiliated private fund institutions, with total confiscations and fines exceeding 41 million yuan. Sun Wei, the actual controller of Ruifengda, was subjected to a lifetime ban from the securities market. This scale of penalties sets a new record for administrative punishment in the private fund sector, making it the "heaviest penalty ever." This concentrated crackdown on Ruifengda and a batch of other private fund institutions is not a special campaign but the result of regulators' normalized and severe crackdown on illegal activities. With the deepening implementation of the "Regulations on the Supervision and Administration of Private Investment Funds," a three-dimensional accountability network covering "self-regulation, administrative, and criminal" aspects is being woven ever tighter, aiming to fundamentally correct industry malpractices and steer the private fund industry back to its origin of "managing money on behalf of clients." The cases highlighted in this concentrated announcement directly target egregious behaviors by private funds that cross regulatory "red lines," including illegal fundraising, misappropriation of funds, self-dealing, and related-party transactions for improper benefits. Regulators have not only imposed heavy fines but have also simultaneously canceled the manager registrations of the involved entities and transferred suspected criminal线索 to public security authorities, achieving a comprehensive and penetrating punishment of both the violating entities and responsible individuals. In the view of industry insiders, this marks that private fund regulation has entered a new phase characterized by being "sharp and thorny," continuously releasing a strong signal that "regulation will never be absent, and violations will be severely punished." This creates a fair competitive environment for law-abiding and compliant institutions and builds a strong institutional levee to protect the legitimate rights and interests of investors.

The heavy punch against the "Ruifengda Case" demonstrates penetrating supervision, three-dimensional accountability, and penalties that instill awe. The "heaviest penalty ever" imposed on Ruifengda and its actual controller Sun Wei is the centerpiece of this regulatory action, most clearly outlining the current "firepower" and precision of private fund supervision. According to the CSRC's investigation, Ruifengda and its related private fund institutions and responsible persons were found to have committed multiple serious illegal activities. The core violations first point to severe inaccuracies in information reporting. Ruifengda and its affiliates, including Hunan Beichen Yuren, Changzhou Fangzhan, Jiangsu Ruizhu, and Shanghai Zhengran, among other private fund institutions, submitted information regarding their actual controllers and affiliated parties to the Asset Management Association of China (AMAC) that was inconsistent with the actual situation. This systematic, organized information falsification aimed to conceal the true control relationships and related-party transaction networks, evading regulatory oversight, and served as a prerequisite for engaging in more concealed illegal activities. Deeper-level violations touched upon the fundamental bottom lines of the private fund business. The investigation found that multiple fund products managed by institutions such as Shanghai Riying and Hunan Beichen Yuren had substantial amounts of raised capital that were not operated according to the investment directions and strategies stipulated in the fund contracts. This essentially constituted fraud against investors, as the funds may have been misappropriated for self-financing by related parties, improper benefit transfers, or other high-risk areas. Particularly egregious was the fact that Ruifengda's actual controller, Sun Wei, personally intervened, using his own name or entities under his control to promise some investors in funds under Ruifengda and Changzhou Fangzhan that their principal would not suffer losses or to guarantee minimum returns. It is important to note that "no public fundraising and no promises of returns" are basic requirements for private funds; any private fund product that directly or indirectly promises "capital preservation and guaranteed returns" carries significant misleading risks, and investors should exercise caution. In the face of such serious and egregious violations, the Shanghai Securities Regulatory Bureau imposed combined confiscations and fines of over 28 million yuan on Ruifengda and its affiliated private fund institutions, fined five responsible individuals including Sun Wei more than 13 million yuan, and imposed a lifetime securities market ban on Sun Wei. This means Sun Wei can no longer engage in securities business in any institution or hold positions as a director, supervisor, or senior executive in a listed company, effectively ending his career in the capital markets. Simultaneously, the AMAC canceled the manager registrations of the relevant private fund institutions; for potential criminal线索 involved in the illegal activities, the regulators will adhere to the principle of "transferring all that should be transferred," referring them to public security authorities for criminal investigation according to law. From maximum administrative penalties to a lifetime industry ban, and the "backstop" of criminal accountability, the handling of the Ruifengda case showcases the current three-dimensional accountability system in the private fund sector, integrating "self-regulation management, administrative supervision, and criminal enforcement." This increasingly tight net aims to ensure that serious violators at any level have nowhere to hide and pay the due price. The 41 million yuan in confiscations and fines far exceeds the previous record case of Youce (35 million yuan), and its warning significance is self-evident: any attempt to defraud investors through means such as concealing actual control relationships, misappropriating fund assets, or illegally promising returns will face the thunderous strike of regulators. The group of cases reveals a spectrum of industry malpractices: intertwining of conduit operations, capital idling, and fraud. Besides Ruifengda, five private fund institutions associated with its illegal activities were also penalized simultaneously. These cases, together with the latest typical cases of disciplinary actions released by the AMAC, collectively outline the core areas of violation targeted by the regulatory sword, revealing a spectrum of malpractices where some institutions' businesses exhibit intertwined issues of acting as "conduits," funds engaging in "idling," and fraudulent conduct. The absence of management responsibilities has become a chronic ailment highlighted in this round of penalties. After filing a product, Guangdong Jumi completely delegated the core investment management duties to a third party, reducing itself to a nominal "conduit." The situations at Shanghai Junguan and Shanghai Zeheng were equally alarming: the products they managed, from investors to investment targets, were entirely arranged by third parties, with funds circulating idly among private fund products controlled by related parties, while the managers neglected their duties, becoming mere figureheads. Such behaviors trample on the fiduciary duty of managers to "manage money on behalf of clients and act in their best interests," distorting private funds into covert tools for evading regulation and conducting improper benefit transfers, harboring enormous risk black holes. Accompanying the dereliction of duty is a severe loss of control over fund utilization and contractual fraud. The case of Shanghai Riying is highly representative. Over a period of three years, some of the raised capital from 14 fund products it managed openly deviated from the investment paths stipulated in the contracts. This means that the investment decisions made by investors based on publicly transparent contract terms were unilaterally and arbitrarily distorted by the manager, leaving the actual destination of the funds a mystery. This constitutes not only a fundamental breach of contractual obligations but also a direct infringement of investors' right to information and property rights. The hefty fine of 14 million yuan imposed by regulators clearly conveys a firm stance of "zero tolerance" for such direct fraudulent behavior. Violations at a more micro level are also eroding the foundation for the industry's healthy development. Cases reported by the AMAC show that违规 operations by some private fund institutions have permeated into minute details. Some institutions lent out accounts of fund products they managed for trading by external personnel; others engaged in falsification in the management of employee qualifications, assisting non-staff personnel in registering for fund从业资格 through "academic qualification recognition";还有一些从业人员在销售环节诱导投资者修改风险评估结果， deliberately circumventing suitability management requirements, sowing the seeds for disputes from the outset. The AMAC has taken self-regulatory disciplinary actions against such behaviors, including revoking registrations, canceling qualifications, and blacklisting, forming a tight synergy with administrative supervision. This series of cases clearly indicates that current private fund supervision has formed an all-encompassing,死角-free monitoring and enforcement posture. Whether it involves macro-level fund misappropriation and idling, meso-level contract breaches and dereliction of duty, or micro-level operational misconduct and qualification fraud, any action that crosses the regulatory red line will face severe consequences.

Viewing the regulatory脉络 through the "heaviest ever" penalty: Legalization upgrade and normalized deterrence. Through the penalties imposed on Ruifengda and its five affiliated private fund institutions, it can be seen that private fund regulation is advancing in-depth along a path characterized by legalization, normalization, three-dimensionality, and the combination of punishment and prevention. Currently, strict supervision has entered a normalized and long-term operational track. It is understood that this concentrated punishment is not the result of a short-term special campaign but a routine manifestation of regulators' "zero tolerance" and maintained high-pressure stance. Relevant data shows that in 2025, regulatory inspections covered a wide range, with hundreds of institutions and individuals facing administrative监管 measures, dozens of cases being investigated, and multiple线索 referred to judiciary. The significant increase in the frequency and intensity of enforcement means that "supervision with teeth and thorns" has become a stable market expectation and daily ecosystem, aiming to completely dispel any sense of侥幸心理 among institutions. It is noteworthy that a three-tiered, organically connected立体追责 system of "self-regulation, administrative, and criminal" aspects has taken shape. Observing the处置 process of the Ruifengda case, a clear collaborative chain is visible: the AMAC swiftly canceled the manager registrations, completing the clearance at the self-regulatory level; the CSRC and its local offices imposed maximum administrative penalties according to law, implementing惩戒 at the administrative level; for线索 suspected of crimes, they were resolutely transferred to public security authorities, initiating criminal prosecution procedures. This layered, categorized, and interlocking integrated处置 mechanism constitutes a closed-loop打击 and strong deterrence against illegal and违规 activities. While严厉惩治 is underway, educational guidance and efforts to promote industry规范化发展 are also advancing. The ultimate goal of regulation is not only to清除毒素 but also to promote the health of the organism. It is understood that in 2025, the entire industry carried out over a thousand publicity and education activities, covering a large number of从业人员. The AMAC regularly publishes typical cases of disciplinary actions, aiming to leverage the警示作用 of "using cases to interpret the law," helping institutions and从业人员 accurately understand regulatory rules and clarify behavioral boundaries; entering 2026, regulators will continue to urge private fund institutions to conduct in-depth self-inspections and corrections, focusing on rectifying chronic issues such as acting as conduits and违规代持. In the view of industry insiders, from a record-breaking penalty to a series of deeply analyzed cases, China's private fund regulation is continuously purifying the market ecology with systematic thinking and firm execution. This increasingly dense three-dimensional protective net serves both as a severe crackdown on violators and a powerful escort for compliant and trustworthy actors, laying a solid foundation of integrity and institutional guarantee for the private fund industry.