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Listed banks intensively appoint Chief Compliance Officer, and the banking industry's compliance governance may face deeper changes

2026-03-03   

As of March 2nd, nearly 30 listed banks have announced the appointment of their Chief Compliance Officers. Among them, several banks including Agricultural Bank of China, China Construction Bank, Bank of China, Lanzhou Bank, and Qingnong Commercial Bank announced that the Chief Compliance Officer will be concurrently held by the President. Industry insiders believe that the establishment of a Chief Compliance Officer is not only an important measure for banks to respond to regulatory policies, but also promotes the deep reshaping of the compliance management system in the banking industry, which is conducive to the transformation of banks from "passive regulatory compliance" to "active compliance governance". Compliance starts from the top management of banks. Recently, listed banks have issued numerous announcements regarding the appointment of their Chief Compliance Officers. On February 27th, five listed banks announced their candidates for Chief Compliance Officers. Except for Liu Jianjun, the Chief Risk Officer appointed by Bank of Communications, who also serves as the Chief Compliance Officer, the Chief Compliance Officers of Construction Bank, Zhejiang Commercial Bank, Lanzhou Bank, and Qingnong Commercial Bank are all held by their respective presidents. Among them, the appointment qualification of Lv Linhua of Zhejiang Commercial Bank will take effect after his qualification as the president is approved. On February 13th, Agricultural Bank of China announced the appointment of its President Wang Zhiheng as the Chief Compliance Officer; On the same day, Bank of China released a board resolution announcement appointing its President Zhang Hui as the Chief Compliance Officer. On February 12th, Everbright Bank announced that its board of directors has agreed to appoint Yang Wenhua as the bank's Vice President and Chief Compliance Officer. From the current positions of Chief Compliance Officers appointed by various banks, most of them are concurrently held by the President, while some banks also appoint senior executives such as Vice Presidents, Chief Risk Officers, and Assistant Presidents as Chief Compliance Officers. Some banks adopt a full-time Chief Compliance Officer model. The relevant person in charge of the State Administration for Financial Regulation stated in a previous press conference that financial institutions need to improve their ability to operate in accordance with the law and regulations, and organically integrate compliance management into their corporate governance system, operational management structure, and business processes. This requires compliance to start from the top and promote the effective operation of the compliance management system at a high level. Compliance management should have seriousness and independence. Industry insiders have analyzed that the recent intensive appointment of Chief Compliance Officers by banks is mainly in response to the relevant requirements of the "Compliance Management Measures for Financial Institutions" issued by the State Administration of Financial Supervision and Administration in December 2024. The measures will be implemented from March 1, 2025, with a transition period of one year. The method specifies that financial institutions should establish a Chief Compliance Officer at their headquarters, who can be appointed separately based on their own business situation or concurrently by senior management personnel. ”The relevant person in charge of the office of the board of directors of a state-owned large bank stated that senior executives serving as chief compliance officers are beneficial for financial institutions to fulfill their compliance duties from the top, cultivate a compliance culture, enhance the compliance awareness of all employees, create a compliance environment where they dare not violate regulations, cannot violate regulations, and do not want to violate regulations, effectively ensuring high-quality development. The regulations require that the Chief Compliance Officer and Compliance Officer shall not be responsible for managing the front-end business, finance, fund utilization, internal audit, and other departments of financial institutions that may conflict with compliance management responsibilities. Except for financial institution presidents (general managers) who also serve as chief compliance officers, provincial or first level branch presidents (general managers) who also serve as compliance officers. The relevant person in charge of the State Administration for Financial Regulation stated that the core essence of compliance is to follow laws, regulations, and regulatory norms, without touching the "bottom line" or "red line", which requires compliance management to have corresponding seriousness and independence. Experts generally believe that the establishment of a Chief Compliance Officer by banking institutions marks a new stage in the compliance governance of the banking industry. Under the guidance of the regulations, financial institutions should establish a horizontal to edge and vertical to bottom compliance management system, injecting compliance genes into the entire process and field of financial institution development decision-making and business operations, and achieving a transformation from "passive regulatory compliance" to "active compliance governance". The special nature of financial institutions determines that their compliance management requirements are higher than those of general enterprises. ”Dong Ximiao, Chief Economist of Zhaopin and Deputy Director of Shanghai Finance and Development Laboratory, believes that financial institutions must adhere to compliant operations, cultivate a compliant culture, guide employees to enhance their risk and compliance awareness, continuously improve their compliance level, and effectively prevent and control business risks. From the specific requirements proposed in the regulations, the Chief Compliance Officer of a bank should bear specialized leadership responsibility for the compliance management of the institution and its employees. The compliance management responsibilities they perform mainly include: being responsible for the compliance management work of the institution, organizing and promoting the construction of the compliance management system, supervising the performance of the compliance management department and compliance positions, and organizing and promoting the strict implementation and effective implementation of compliance norms within the institution; Organize and promote the establishment of compliance management systems, compliance reviews, compliance inspections and evaluations, handling of major compliance incidents, compliance assessments, problem rectification, and team building to ensure the orderly operation of compliance management work; Regularly report to regulatory agencies as required. (New Society)

Edit:Luoyu Responsible editor:Zhoushu

Source:China Securities Journal

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