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China Country Summary

Sanctions

High Concern

FATF AML Deficient List

Low Concern

Terrorism

Medium Concern

Corruption

Medium Concern

US State ML Assessment

High Concern

Criminal Markets (GI Index)

Medium Concern

EU Tax Blacklist

Low Concern

Offshore Finance Center

Low Concern

Please note that although the below Summary will give a general outline of the AML risks associated with the jurisdiction, if you are a Regulated entity then you may need to demonstrate that your Jurisdictional AML risk assessment has included a full assessment of the risk elements that have been identified as underpinning overall Country AML risk. To satisfy these requirements, we would recommend that you use our Subscription area.

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Anti Money Laundering

FATF Status

China is not on the FATF List of Countries that have been identified as having strategic AML deficiencies

Compliance with FATF Recommendations

The last follow-up Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in China was undertaken in 2022. According to that Evaluation, China was deemed Compliant for 9 and Largely Compliant for 22 of the FATF 40 Recommendations. It remains Highly Effective for 0 and Substantially Effective for 3 of the Effectiveness & Technical Compliance ratings.

Sanctions

China implements two types of economic sanctions: those mandated by the United Nations and its own counter-sanctions against foreign entities. The Ministry of Foreign Affairs and the Ministry of Commerce are responsible for administering and enforcing these sanctions, particularly in relation to contested territories like Taiwan and Hong Kong.

The U.S. has imposed sanctions on Chinese entities for dealings with blacklisted Russians and issued an Executive Order to restrict investments in Chinese military companies. The EU maintains an arms embargo against China, citing human rights concerns, while the UK warns of attempts by Russia to circumvent sanctions through intermediary countries, including China.

Criminality

Rating

0 (bad) - 100 (good)
Transparency International Corruption Index 43
World Bank: Control of Corruption Percentile Rank 54

Since 2012, China has implemented a significant anti-corruption campaign led by the CCP, which has expanded its investigatory reach to include not only party officials but also government employees and managers of state-owned enterprises. The National Supervisory Commission-Central Commission for Discipline Inspection (NSC-CCDI) has reported investigating millions of cases and recovering billions in corruption-related funds, while recent laws have increased penalties for corruption. Despite these efforts, the application of anti-corruption measures appears inconsistent, and civil society's role in investigating corruption remains limited.

Economy

In 2023, China's economy faced challenges as inbound foreign direct investment (FDI) dropped to $163 billion, marking a 13.7 percent decline from the previous year. Factors contributing to this downturn included a slower-than-expected economic recovery post-COVID-19, regulatory unpredictability, and geopolitical tensions, particularly with the U.S. Despite these issues, China remained the fourth-largest FDI destination globally, with ongoing efforts to improve the foreign investment environment through tax incentives and regulatory reforms.

In 2023, China's investment climate faced challenges as foreign direct investment (FDI) fell to $163 billion, marking a 13.7% decline from the previous year, attributed to a slower economic recovery post-COVID-19, regulatory unpredictability, and geopolitical tensions. The PRC remains the 11th most restrictive country for FDI, with significant barriers such as foreign ownership caps and joint venture requirements, which deter foreign investors. Despite these challenges, the government has made efforts to improve the foreign investment environment, including extending tax holidays for foreign investors until 2027.

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