New anti-money laundering regulations highlight East Turkestan prevention and control, with virtual assets included in the regulatory scope

In January 2026, the People’s Bank of China, in conjunction with the Ministry of Foreign Affairs, Ministry of Public Security, and six other departments, officially issued the “Administrative Measures for Special Anti-Money Laundering Preventive Measures.” This new regulation was reviewed and approved at the Central Bank’s Executive Meeting on November 17, 2025, and will come into effect on February 16, 2026. As an important supporting document to the “Anti-Money Laundering Law (2024 Revision),” the measures clarify for the first time, through list management and full-process control, the specific scope of application, implementation standards, and responsibilities for the special anti-money laundering preventive measures. This further strengthens the anti-money laundering, counter-terrorism financing, and proliferation financing prevention system, posing unprecedented compliance challenges for financial institutions and certain non-financial entities.

Clarification of the “Blacklist System” for Anti-Money Laundering: Establishing a Three-Mechanism Prevention System

The core innovation of this new regulation is the first formal establishment of a “blacklist system” for anti-money laundering. The blacklist is jointly maintained by three+one national-level entities: the National Counter-Terrorism Leadership Group, the Ministry of Foreign Affairs, the People’s Bank of China, and relevant foreign agencies coordinated by the People’s Bank of China.

First, the Office of the National Counter-Terrorism Leadership Group is the main channel for releasing lists of terrorist activities. Historically, lists of terrorist organizations and individuals announced annually fall into two categories: one includes separatist groups like the East Turkestan Islamic Movement and related personnel; the other includes other terrorist organizations and individuals. Notably, the sanctions lists issued by the Ministry of Public Security in March 2003, April 2008, and May 2012 involve four organizations and 25 individuals. These terrorist organization lists are considered sensitive information, and in most cases, there are no public access channels. Relevant institutions and individuals should monitor official announcements from the Office of the National Counter-Terrorism Leadership Group.

Second, the Ministry of Foreign Affairs plays a special role within this system, mainly fulfilling international legal obligations in accordance with UN Security Council resolutions. For example, the “Notice on the Revision of Listing of Individuals by the UN Security Council’s Sanctions Committee on ‘Islamic State’ and ‘Al-Qaeda’” issued on October 7, 2025, reflects cooperation with the UN Security Council’s 1267 Committee sanctions. Additionally, the Ministry has issued notices related to UN Security Council resolutions concerning North Korea (Resolutions 1695, 1718, 2397), Iran (Resolution 2402), and others, all of which fall within the scope of this anti-money laundering regulation.

Finally, the People’s Bank of China, alone or jointly with relevant national agencies, maintains lists of organizations and individuals with significant money laundering risks or those whose non-action could cause serious consequences. These lists are mainly divided into two categories: one is the international blacklist, primarily from the Financial Action Task Force (FATF), accessible via the FATF website under “High-risk and other monitored jurisdictions”; the other is the domestic blacklist, found in the “Anti-Money Laundering” section of the PBOC official website under “Risk Alerts and Financial Sanctions.”

For banks, payment institutions, and other financial entities, managing these three types of lists has become routine. The new regulation further clarifies the legal status and specific requirements for these operations.

How to Query and Respond to the East Turkestan and Other Terrorist Organization Lists

Financial institutions and enterprises need to understand how to accurately access and utilize lists related to East Turkestan and other terrorist organizations in their daily operations. Different types of lists require different query and response methods.

For lists issued by the Office of the National Counter-Terrorism Leadership Group, monitor official announcements for updates and regularly update internal blacklists. These lists involve separatist groups like the East Turkestan Islamic Movement and are critical for anti-money laundering work.

For lists related to UN Security Council resolutions issued by the Ministry of Foreign Affairs, promptly consult the United Nations official website for the latest information and cross-reference with relevant notices published by the PBOC to ensure accuracy and completeness.

For lists maintained by the PBOC, establish regular query and update mechanisms to keep partner information in a “white list” status at all times.

Blacklists Are Not the End: Three Relief Channels to Try

If mistakenly placed on an anti-money laundering blacklist, there are pathways to seek relief. Article 9 of the new regulation specifies procedures for different types of lists, though operational details vary significantly.

For lists issued by the Office of the National Counter-Terrorism Leadership Group, individuals can apply for review according to the “Counter-Terrorism Law of the People’s Republic of China.” However, given the sensitivity of East Turkestan and related issues, the success rate for relief is extremely low, and removal through conventional channels is nearly impossible. Similarly, if the list is a UN Security Council sanctions list, removal depends on UN resolutions, not solely on China’s regulatory agencies.

For lists published by the Ministry of Foreign Affairs, applicants can submit removal requests following official procedures. Success rates are also low, requiring substantial evidence proving no involvement in terrorist activities.

For lists identified solely or jointly by the PBOC and other departments, relief prospects are relatively better. Affected parties can request administrative reconsideration from the agency that made the determination; if dissatisfied, they can file administrative litigation. With legal assistance, gathering sufficient objective evidence and pursuing judicial remedies offers a reasonable chance of success.

Scope of the New Regulation: Full-Chain Compliance from Institutions to Individuals

The “Administrative Measures for Special Anti-Money Laundering Preventive Measures” further refine Article 40 of the “Anti-Money Laundering Law (2024 Revision),” which states that “any entity or individual shall take special anti-money laundering preventive measures for objects listed in the lists as required by relevant national authorities.” This means the regulation covers financial institutions, certain non-financial entities, enterprises, and individuals.

For individuals, the primary advice is not to lend out ID cards or bank cards. If others use your ID to open accounts or conduct money laundering, once linked to a blacklist, all your legitimate assets could be restricted or transferred. Although Article 4 emphasizes protecting the rights of good-faith third parties, proving “good faith” can be time-consuming and difficult.

For enterprises, especially those involved in cross-border trade and large transactions, establishing due diligence procedures for partners is essential. Regularly check public blacklist information; if a counterparty appears on the list, immediately cease all services and transfers, and report to relevant authorities. Failure to do so may result in the enterprise being deemed as needing to implement restrictions due to associated risks.

For entities subject to restrictions, the first step is to consult a professional lawyer to clarify the specific blacklist category, actively cooperate with investigations, avoid using or transferring assets, and document recent legitimate transactions. Pursuing legal channels to lift restrictions is advisable.

Virtual Currency Regulation Upgrades: Crypto Assets Are No Longer Outside the Law

Article 29 of the new regulation explicitly states that funds include various forms of assets evidenced electronically or digitally. This means virtual currencies are officially incorporated into the anti-money laundering regulatory framework. Many mistakenly believe virtual currencies can evade AML oversight, which is dangerous.

Crypto assets are within the scope of special anti-money laundering measures. If individuals hold virtual currencies involved in money laundering, they risk freezing or confiscation. Virtual currencies are not a “firewall” against illegal activities; their anonymity and cross-border nature have made them a focus of AML enforcement.

New Pattern for Future Compliance Development

As the new anti-money laundering regulation continues to specify preventive measures, the scope of the blacklist becomes clearer. The future trend of regulation will inevitably be toward penetrating supervision and transparent transactions.

Financial institutions need to quickly improve AML review mechanisms, establish real-time connection with blacklist databases, and proactively cooperate with law enforcement. Enterprises and individuals should operate lawfully, carefully verify trading partners, properly manage accounts, and prevent others from using personal accounts for laundering.

In an era of continuous legal refinement, achieving integrated compliance and risk control will be crucial for market stability and healthy development, forming a shared responsibility among all market participants.