China’s Ministry of Finance, together with the People’s Bank of China, has issued management measures setting out how accounting firms must fulfil anti-money laundering (AML) obligations when providing services covered by Article 64(2) of China’s Anti-Money Laundering Law. The measures also allocate supervisory responsibilities across finance authorities, the AML administrative authority and the CPA profession’s self-regulatory bodies. Accounting firms must establish AML internal controls proportionate to their risk profile, covering risk assessment, customer due diligence (CDD), suspicious transaction reporting, special preventive measures, recordkeeping, confidentiality, training, and internal audit and inspections. CDD must be completed before providing services, with limited flexibility to complete within a reasonable period before the engagement ends where risks are controllable; firms must identify and verify customers (including beneficial owners and agents) and conduct ongoing monitoring. Enhanced CDD is required for higher-risk situations, including customers from high-risk jurisdictions, persons identified by justice or law enforcement bodies as suspected of money laundering-related crime, foreign politically exposed persons and related parties, and other higher-risk cases, and may include obtaining additional information, stronger monitoring, more frequent updates, and senior management approval; firms must refuse or terminate business where high risk persists. Simplified CDD may be used only where risk is assessed as low, but must still include identifying and verifying the customer and beneficial owner. Suspicious transaction reports must be filed regardless of amount through the CPA profession’s unified supervision platform, for onward submission to the China Anti-Money Laundering Monitoring and Analysis Center, and customer and business records must be kept for at least ten years after the business relationship ends. The measures take effect from promulgation and replace any earlier provisions that are inconsistent.
Ministry of Finance (China) 2025-09-03
China's Ministry of Finance and People's Bank of China issue anti-money laundering management measures for accounting firms
China's Ministry of Finance and the People's Bank of China have issued new measures detailing how accounting firms must fulfill anti-money laundering (AML) obligations under Article 64(2) of China's Anti-Money Laundering Law. The measures require firms to establish AML internal controls, conduct customer due diligence (CDD), and report suspicious transactions. Enhanced CDD is mandated for higher-risk situations, while simplified CDD is permitted for low-risk cases, with all records maintained for at least ten years.