Written by: Xiao Za Legal Team

In January 2026, the People's Bank of China, in conjunction with the Ministry of Foreign Affairs, the Ministry of Public Security, and six other departments, officially announced the "Management Measures for Special Preventive Measures Against Money Laundering" (hereinafter referred to as the "Measures"). This measure was approved by the central bank's executive meeting on November 17, 2025, and will officially take effect on February 16, 2026.

As an important supporting system following the implementation of the new "Anti-Money Laundering Law," the "Measures" focus on list management and full-process control, clarifying the scope of application, execution standards, and responsibility boundaries for special preventive measures against money laundering. It further improves China's anti-money laundering, counter-terrorist financing, and financing of weapons of mass destruction prevention and control system, raising compliance operation requirements for financial institutions and specific non-financial institutions.

I. Clarification and Establishment of the Anti-Money Laundering "Blacklist System"

The most eye-catching aspect of the new anti-money laundering regulations is the clarification of the "blacklist system" for special preventive measures against money laundering. This blacklist is jointly established by three plus one entities in China, namely:

(1) The National Anti-Terrorism Work Leading Group;

(2) The Ministry of Foreign Affairs;

(3) The People's Bank of China;

(4) The People's Bank of China in conjunction with relevant national authorities.

The Xiao Za team will analyze each entity one by one.

First is the National Anti-Terrorism Work Leading Group, whose office is the main channel for publicly releasing the announced lists. So far, the announced lists of terrorist organizations and individuals mainly include two categories: (1) Lists of East Turkestan terrorist organizations and individuals; (2) Lists of other terrorist organizations and individuals. Currently, it is clear that the Ministry of Public Security has released three batches of sanctions lists targeting the separatist forces of the East Turkestan Islamic Movement in March 2003, April 2008, and May 2012, involving four organizations and 25 individuals. As of now, there are not many publicly available lists, mainly because the lists of terrorist organizations and individuals are considered sensitive information, and there may not be public inquiry channels available. Partners can pay attention to the announcements released by the office of the National Anti-Terrorism Work Leading Group for analysis and understanding.

Next is the Ministry of Foreign Affairs, which is somewhat special, as it mainly cooperates to fulfill international legal obligations in accordance with the requirements of United Nations Security Council resolutions. For example, the Ministry of Foreign Affairs issued a notice on October 7, 2025, regarding the revision of personal information on the sanctions list of the United Nations Security Council's "Islamic State" and "Al-Qaeda" sanctions committee, which pertains to the implementation of the UN Security Council's sanctions against the "Islamic State" and "Al-Qaeda." The specific list can be confirmed by checking the United Nations official website. Other notices issued by the Ministry of Foreign Affairs regarding the implementation of UN Security Council resolutions related to North Korea, such as 1695, 1718, 2397, and 2402 related to Iran, also fall within the scope of the new anti-money laundering regulations.

Finally, there is the list of organizations and individuals identified solely by the People's Bank of China or in conjunction with relevant national authorities, which pose significant money laundering risks and may cause serious consequences if no measures are taken. This publicly available list is mainly divided into two parts:

(1) The international blacklist mainly comes from the Financial Action Task Force (FATF). By logging into the FATF official website and finding "High-risk and other monitored jurisdictions" under the "publications" section, you can obtain the latest list;

(2) The domestic blacklist comes from the People's Bank of China's official website. By logging into the central bank's official website and finding "Risk Alerts and Financial Sanctions" under the "Anti-Money Laundering" section, you can obtain the latest list.

Overall, banks, payment companies, and other financial institutions, as the main bearers of anti-terrorism and anti-money laundering obligations, are already quite familiar with the three types of lists mentioned above. The new regulations further clarify the work content of anti-terrorism and anti-money laundering.

II. Is There a Way Out After Being Listed on the Anti-Money Laundering Blacklist?

The Xiao Za team has found that during the handling of numerous cases involving the unfreezing of large overseas cryptocurrency assets, some foreign institutions may be blacklisted by judicial and law enforcement agencies in various countries and jurisdictions for various reasons (large risk transactions, secondary sanctions on transaction counterparts, suspicious fund flows, etc.).

So, if one is placed on China's anti-money laundering "blacklist," are there any remedies available?

According to Article 9 of the new regulations, depending on the administrative authority that identifies and publishes the relevant lists, entities on the Chinese version of the "Anti-Money Laundering and Counter-Terrorist Financing Blacklist" can apply to the National Anti-Terrorism Work Leading Group, the Ministry of Foreign Affairs, or the People's Bank of China. However, the specific operation needs to be discussed based on the situation.

According to Article 9 of the "Management Measures for Special Preventive Measures Against Money Laundering," if there are objections to the list specified in Item 1 of Article 2 of these measures, the parties can apply for a review through the office of the National Anti-Terrorism Work Leading Group in accordance with the relevant provisions of the "Anti-Terrorism Law of the People's Republic of China." If there are objections to the list specified in Item 2 of Article 2 of these measures, the parties can submit a delisting application according to the procedures published by the Ministry of Foreign Affairs. If there are objections to the list specified in Item 3 of Article 2 of these measures, the parties can apply for administrative reconsideration to the department that made the identification; if they are dissatisfied with the administrative reconsideration decision, they can file an administrative lawsuit in accordance with the law.

First, it is important to clarify that if one is on the first type of announcement list from the National Anti-Terrorism Work Leading Group's office or the second type of sanctions list published by the United Nations Security Council, the remedies specified in the new regulations use the terms "apply for review" and "submit a delisting application," which basically means that it is unlikely to be resolved, and there are essentially no lawyers or relevant professionals who can provide "delisting" services. Additionally, if it falls under the second type of being listed on the sanctions list by the United Nations Security Council, whether "delisting" can be achieved depends on the resolutions of the United Nations Security Council, which cannot be decided solely by China's regulatory authorities.

Secondly, if one is on the list identified solely by the People's Bank of China or in conjunction with other departments, there is a certain probability of being able to "prove one's innocence." It is worth noting that entities on such lists have the right to initiate administrative reconsideration or administrative litigation. In this case, with the assistance of lawyers, the relevant entities should collect objective evidence and may attempt to seek remedies through judicial channels, with a certain chance of success.

III. Who Will Be Affected After the New Regulations Are Officially Implemented?

The new regulations are essentially a refinement of the "special preventive measures against money laundering" introduced in Article 40 of the "Anti-Money Laundering Law (2024 Revision)," stating that "any unit and individual shall take special preventive measures against money laundering for the objects listed in the following lists as required by relevant national authorities." Clearly, "any unit and individual" includes financial institutions, specific non-financial institutions, as well as enterprises and individuals.

The Xiao Za team reminds partners:

First, do not lend your ID card and bank card. If someone uses your ID card to open an account or directly uses your bank card for money laundering activities, once you enter the aforementioned "blacklist," all your legally owned personal property will be restricted from use and transfer. Even though Article 4 of the new regulations emphasizes the protection of the legitimate rights and interests of good-faith third parties, it will still require a lot of time and effort to prove that one meets the "good faith" standard.

Second, companies should strengthen their due diligence obligations towards partners. If you are a company involved in cross-border trade or large transactions, you need to pay more attention to the due diligence of partners than before. Establish a list review system based on publicly available channels, and once you find that a counterpart has entered the "blacklist," stop all services and transfers immediately, and report to the relevant departments in a timely manner; otherwise, you may also be deemed to have taken restrictive measures against related companies.

Third, if you find yourself on the "blacklist" and subject to restrictive measures, consult a lawyer immediately to determine the specific category of the "blacklist," cooperate with relevant departments in the investigation, and do not use or transfer personal assets held, while organizing records of legitimate transactions in recent times, and attempt to lift the "special measures" through specific category channels.

Fourth, do not have a fluke mentality regarding virtual currencies. Article 29 of the new regulations clearly states that funds include assets ownership proven in electronic or digital form, and do not use virtual currencies for money laundering criminal activities. Personal holdings of virtual currencies are also within the scope of special measures taken against money laundering; virtual currencies have never been a "firewall" against any illegal activities.

In Conclusion

With the refinement of special preventive measures under the anti-money laundering law, the specific scope of the "blacklist" is becoming increasingly clear. The future trend will certainly be penetrating regulation and transparent transactions. For financial institutions, it is essential to establish an anti-money laundering review mechanism as soon as possible and cooperate with relevant law enforcement agencies to take special measures; for enterprises and individuals, it is crucial to operate lawfully, carefully identify transaction counterparts, manage one's accounts well, and prevent others from using them for money laundering criminal activities. In the future, achieve an organic unity of business compliance development and risk prevention, and build a solid safety line for the stable and healthy development of the market.

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