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From Fragmentation to Fortress: Regulatory Restructuring and Implications for PRC Banks' Cross-Border Transactions Under CRD 6
The EU's Capital Requirements Directive VI (Directive (EU) 2024/1619, "CRD 6" or the "Directive") entered into force on 9 July 2024 and will be fully implemented from 11 January 2027, introducing authorisation and compliance requirements for branches of third-country institutions. Under the Directive, any non-EU bank that provides "core banking services" within the EU must establish a branch in the relevant EU Member State and apply to the local regulatory authorities for authorisation to provide such services, unless it provides such services through an EU-subsidiary. This means that third-country banks that previously relied on Member State legal exemptions to provide cross-border financial services will no longer enjoy such market-entry convenience. At the same time, EU branches of third-country banks will be brought into a unified minimum EU supervisory framework, covering key dimensions such as capital adequacy, liquidity buffers, and internal governance. Together, CRD 6 and Regulation (EU) 2024/1620 (CRR 3) form a package of EU banking regulation.
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MOFCOM Announces Tiered Listing of 40 Japanese Entities, Significantly Tightening Japan-Related Export Compliance
On 24 February 2026, the Ministry of Commerce of the People's Republic of China ("MOFCOM") issued Announcement No.11 and Announcement No.12 of 2026, simultaneously adding a total of 40 Japanese entities to the Export Control List and the Watch List, respectively. Earlier, on 6 January 2026, MOFCOM had already issued Announcement No.1 of 2026, which imposed broader export control rules on exports of dual-use items to Japan involving Japanese military end users, military end uses, and other end users/end uses that may contribute to enhancing Japan's military capabilities. With these three regulatory measures now in effect concurrently, compliance standards applicable to China-based companies' exports to Japan have become materially more stringent, and regulatory scrutiny has tightened further. In this context, relevant companies face more severe compliance challenges and should strengthen compliance management to ensure that Japan-related export business is conducted in strict accordance with applicable laws and regulations.
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China Tightens Rules for Crypto, RWA Tokenization Included
PRC regulators have long been cautious and closely monitoring the issuance and trading of cryptocurrencies[2] since the advent of Bitcoin in 2008. Aside from the digital yuan (e-CNY) issued by the People's Bank of China ("PBoC"), China continues to reject cryptocurrencies as legal tender and strictly prohibits their circulation in the onshore market. On September 15, 2021, PBoC, along with nine other governmental, party, and judicial organs, issued the PBoC Circular [2021] No.237 (the "2021 Circular"), clearly prohibiting all onshore "cryptocurrency-related business activities". However, the 2021 Circular was silent on real-world asset ("RWA") tokenization, which has since invited curiosity from market participants.
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Han Kun
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