On the afternoon of October 22, 2024, the Law Working Committee of the Standing Committee of the National People's Congress convened a legislative evaluation meeting for the revised draft of the Anti-Money Laundering Law within the premises of the National People's Congress building. In attendance were delegates from the National People's Congress, pertinent state agencies, financial and payment institutions, select non-financial entities, and a number of academic experts from universities. Professor Jia Jidong of the BNU Law School was among the invitees and contributed his expertise during the discussions.

Professor Jia Jidong highlighted that the legislative body has significantly enhanced the previous draft's framework through a process of addition, deletion, reorganization, amalgamation, and separation, thereby refining the logic, precision of language, and the scientific application of legislative techniques. The revised draft underscores the necessity for anti-money laundering efforts to be conducted in accordance with the law, ensuring that such measures are proportionate to the risks of money laundering. It aims to facilitate the smooth operation of normal financial services and fund transfers, protect the legitimate rights and interests of entities and individuals, and fully embody the principles of strengthening financial services and safeguarding legal rights. The draft emphasizes the equilibrium between law enforcement and service provision, achieving a harmonious blend of regulation and spirit.

In essence, the draft is ripe for swift approval, both in terms of content and timing. As international anti-money laundering standards evolve from a "rule-based" to a "risk-based" approach, China's anti-money laundering framework, while maintaining a focus on "self-centeredness," must also align with global benchmarks. This ensures not only compliance with regulatory requirements but also the achievement of effectiveness standards. In the impending fifth round of anti-money laundering mutual evaluations, while technical compliance is expected to be a manageable challenge, the assessment of effectiveness remains a significant test.

The fifth round of mutual evaluations is set to commence in November 2025, with a tight deadline of March 2026 for addressing validity issues. To effectively showcase the compliance and efficacy of China's anti-money laundering system and measures, it is imperative not only to expedite the passage of the revised draft but also to ensure thorough support, monitoring, evaluation, and enhancement of the system post-implementation.

Firstly, the State Council's anti-money laundering authority must promptly develop refined supporting regulations and guidelines. Secondly, it is essential to streamline communication channels between anti-money laundering administrative bodies and public security organs to promptly disseminate the outcomes of law enforcement efforts. Thirdly, establishing a robust linkage between the Anti-Money Laundering Law and the Criminal Law is necessary, which involves refining the criminal charging system for money laundering offenses, clarifying the relationship between Articles 191 and 312 of the Criminal Law, and ensuring that relevant cases and data are optimally utilized for evaluation purposes. Fourthly, it is crucial to implement process control and continuous improvement of measures based on monitoring and evaluation outcomes.

He is convinced that swift revision of the draft, the advancement of anti-money laundering law enforcement and judicial processes, and the timely statistical analysis of new case openings will position China proactively for the evaluations, guaranteeing the seamless progression of the anti-money laundering mutual evaluation, particularly in terms of effectiveness assessment.