The People's Bank of China ("PBC") has recently distributed the Circular on Requirements on the Reporting of Large-value Transactions by Non-banking Payment Institutions (the "Circular").
The Circular clearly states that a non-banking payment institution shall calculate unilaterally the cumulative amount of receipts or payments of money for each client, and report four kinds of large-value transactions, including "the receipt or the payment of cash worth over CNY50,000 (inclusive) or over the equivalent value of USD10,000 (inclusive) in a foreign currency for a single transfer or for accumulated transactions on the current day". According to the Circular, for cross-border acquiring business, a non-banking payment institution shall calculate based on the RMB-measured transaction amount paid by the client and submit reports on large-value transactions accordingly; where a client makes payments through an bounded overseas bank card, the non-banking payment institution shall calculate based on the RMB-measured transaction amount settled by the receiving institution and submit reports on large-value transactions accordingly. Furthermore, the Circular specifies that non-banking payment institutions are required to submit reports on large-value transactions in accordance with the Circular beginning from January 1, 2019.