The Measures align precisely with the relevant provisions on customer due diligence and beneficial owner information management. By establishing a unified standard for beneficial owner identification, developing a risk-based differentiated mechanism, and forming a regulatory closed loop, the Measures enhance the practical capabilities of financial institutions in anti-money laundering (AML) and counter-terrorist financing (CTF), and effectively ensure the compliant operation and transparent development of financial businesses. The core points are as follows:

• Scope of application: it applies to all financial institutions required to perform customer due diligence, including banks, securities firms, insurance companies, and payment institutions.

• Core principles and applicable subjects: Financial institutions shall follow the three principles of "risk-based, reasonableness, and reliability" to conduct identification and verification of beneficial owners for all non-natural person customers (excluding individual industrial and commercial households).
• Clear identification standards for beneficial owners are established, with strengthened requirements for penetration verification to ensure tracing back to the ultimate natural persons.

1. 1）Legal persons and non-legal person entities: the identification standards are consistent with the Administrative Measures for Beneficial Owner Information. A beneficial owner is identified if any of the following conditions are met: a) direct or indirect ultimate ownership of over 25% of equity/rights; b) entitlement to over 25% of profit rights/voting rights; c) sole or joint de facto control. If none of the above conditions apply, the person responsible for daily operations and management shall be identified as the beneficial owner.
2. 2）Branches: Domestic branches directly adopt the beneficial owner information of their head companies. For branches of foreign companies, in addition to identifying the beneficial owners of the head companies, at least one local senior executive shall be identified as a beneficial owner.
3. 3）Trusts: Trust parties (settlors, trustees, beneficiaries, etc.) or other natural persons exercising ultimate effective control over the trust.
4. 4）Asset Management Products: Refer to the identification standards for legal persons and non-legal person entities.

• Standardize the requirements for beneficial owner identification and verification.

1. 1）Clarify the overall process and requirements for identifying and verifying beneficial owners, as well as the information elements to be identified and retained.
2. 2）Adopt differentiated identification and verification measures based on risk: Exemptions or simplified procedures may apply to low-risk scenarios, while enhanced measures shall be taken for high-risk scenarios (e.g., customers/transactions from high-risk countries, overly complex equity structures preventing verification, frequent and unjustified changes in senior management /beneficiaries). If a financial institution’s risk management capacity is exceeded even after setting limits on transaction amounts, frequency, or product types, it shall refuse or terminate the business relationship.
3. 3）High-Risk Association Analysis: When a natural person customer is identified as high-risk, the financial institution shall screen all non-natural person customers for whom that individual acts as a beneficial owner within the institution, conduct association analysis, and implement necessary customer due diligence or anti-money laundering risk management measures.

    4）Ongoing Requirements: Throughout the customer’s business relationship, financial institutions shall continuously monitor the customer’s overall status and transaction activities, updating beneficial owner information in a timely manner.