Field Memo

Deep dives into the legal and regulatory shifts shaping China’s financial landscape.

Field Memos explain how rules change in practice and what it implies for your structures, compliance posture, and operating model.

[D] Capital Deployment

What we cover:

Operational mechanics of ODI, FX controls, cross-border M&A, and private wealth structures.

For: @CFO · @Treasurer · @WealthManager · @FamilyOffice · @TransactionLawyer

[C] Risk & Control

What we cover:

Specific compliance triggers, supervisory expectations, and liability exposure under new rules.

For: @CRO · @GeneralCounsel · @ComplianceOfficer · @InternalAuditor · @RiskAdvisor

[A] Architecture & Infrastructure

What we cover:

Technical specifications for compliant system design—API gateways, data localization, observability graphs, and AI governance frameworks.

For: @CIO · @CTO · @DataOwner · @RegTechBuilder · @InfoSecLead

All [G] Gauge & Sovereignty [D] Capital Deployment [C] Risk & Control [A] Architecture & Infrastructure

[C] Risk & Control

Can Product Expansion Upgrade China’s RMB Pricing Capacity? — New Regulation Establishes a Quality-First Paradigm

Nine rule mechanics and a futures-vs-spot comparison explain why the revised Futures Supervision Regulation entrenches integrated futures-spot governance — not blanket product liberalisation.

Read → [C] Risk & Control · [D] Capital Deployment

Is Asset-Management Disclosure Truly Unified? — NFRA Harmonisation Entrenches China’s Dual-Track Regime

Seven rule mechanics and a NFRA-vs-CSRC comparison reveal why dual-track AM disclosure — not full-sector unification — is China’s permanent steady state.

Read → [C] Risk & Control · [D] Capital Deployment

De-Financializing Property: The Regulatory Playbook for China’s Real Estate Reset

Five regulatory pillars — project ring-fencing, mortgage reform, statutory risk separation, credit red lines, and phased transition — that permanently rewire China’s property financing system.

Read → [A] Architecture & Infrastructure

Sovereignty Reclaims Market Flows: CAC’s Tiered Data Regime & Global Asset Manager Reset

A 67-item catalogue, four-tier data grading, and six-authority joint filing — how Circular No.2 [2026] rewires cross-border financial data infrastructure for global asset managers.

Read → [C] Risk & Control · [A] Architecture & Infrastructure

The Five Gates: Reshaping China Quant

Execution frequency, market conduct, infrastructure access, UBO penetration, algorithm registration — five sequential gates that determine whether you can trade at all.

Read → [D] Capital Deployment

The Offshore Illusion is Over: Reading China’s Trust Tax Through Two Lenses

Three tax nodes, four political dimensions, and where the real negotiation happens — the offshore trust is no longer a black box.

Read → [D] Capital Deployment

Three Rewrites of Oversea Investment Under Decree 837

Subject, conduct, and jurisdiction — how a single ordinance restructures the entire outbound-investment framework.

Read → [C] Risk & Control

The Three Triggers Beneath the Draft of China’s Financial Law

Assist, International Organizations, Personal Accountability — three clauses that rewire the compliance circuit board.