Recently, the Ministry of Justice (MOJ) and the People's Bank of China (PBC) have jointly issued the Administrative Measures for Anti-Money Laundering in the Legal Profession (the "Measures"), which shall take effect on the date of issuance.
According to the Measures, law firms should assess their money laundering risks and, based on the assessment results, adopt measures to manage and mitigate the identified money laundering risks. They are also required to establish customer due diligence (CDD) systems. If a law firm accepts an engagement of a client to provide legal services involving matters specified in subparagraph 2 of Article 64 of the Anti-Money Laundering Law of the People's Republic of China (Revised in 2024), CDD must be conducted. The Measures further stipulate that law firms, comprehensively considering factors such as client characteristics, the content of engaged matters, and the source and use of funds or assets, shall apply enhanced CDD measures that are commensurate with money laundering risks to clients (such as those from countries or regions with high money laundering risks) and their engaged matters. If a law firm discovers or has reasonable grounds to suspect that a client or engaged matter is involved in money laundering or other related violation and crimes, it shall promptly submit a suspicious transaction report.