Country Manual Private Banking
China – Update 2024

BRP has updated its Country Manual Private Banking for China – (Def, RS, BT & RT)
Source of changes | Answers |
---|---|
Law / Regulation | No |
New Position of the Authorities | No |
Evolution of Expert’s Interpretation | No |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
The Country Manual has been reviewed to ensure that the content of all documents remains accurate and in line with the evolving interpretation of the current legal and regulatory framework.
With respect to the collection of relevant supporting documents and information a slightly more restrictive approach has been taken with respect to activities conducted in the Bank’s country of establishment (YES to a Grey zone YES) to better reflect that both the Data Security Law (DSL) and Personal Information Protection Law (PIPL) apply extraterritoriality to the processing of information outside of the PRC, thus such activities may trigger local data protection regulations even when conducted in the Bank’s country of establishment. For example, Article 3 of the PIPL provides that the PIPL applies to foreign entities offering products and services to individuals located in the PRC, which means that a foreign company should comply with the PIPL when trying to develop business targeting individuals located in the PRC.
Non-material changes
Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “CHINA” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
For more information, please contact us: info@brpsa.com
Geneva, August 13th, 2024