01
Three models of access to the Chinese payment circuit
The choice depends on the license, the volume of RMB payments, customer geography, technical infrastructure and willingness to bear the direct responsibilities of a system participant.
A foreign bank opens an interbank RMB account with a domestic agent bank in mainland China.
Served through a direct participant, receives its own CIPS code and a more specific payment route.
Direct system access for a qualified organization with a significant business, technology and risk framework.
Select markets use a designated RMB clearing bank and associated correspondent relationships.
Payment institution, EMI, fintech, money service business and bank undergo different admission tests. First, the license and allowed functions are checked, then the product is selected.
02
First we define the product, then the bank
- RMB nostro / interbank account
- Cross-border and offshore RMB payments for foreign bank clients
- Commercial payments
- Trade in goods, services, investments and other permissible transactions
- FX conversion
- Buying and selling RMB based on acceptable underlying business
- Liquidity
- Funding, cut-off, intraday management and acceptable credit lines
- Trade finance
- LC, guarantees, collections and documentary operations with separate approval
- Other currencies
- USD, EUR and other currencies depend on the product, license and appetite of a particular bank
03
Qualification of a foreign bank
The Chinese correspondent verifies that the applicant is legally established, has a valid banking or other relevant license, is under effective supervision, and is authorized to carry out the stated cross-border payments.
- Legal status
- Legal Entity or Eligible Regulated Subdivision
- License
- Valid banking and payment authorities in the country of establishment
- Regulator
- Supervisory authority, inspection results and license status
- Capital
- Prudential indicators, reporting and ability to manage liquidity
- Reputation
- Enforcement, significant fines, litigation and adverse media
- Business case
- Real clients, RMB flows, countries, volume and growth forecast
04
The correspondent must be suitable for the payment route
The size of a Chinese bank alone does not guarantee a suitable product. Direct participation in CIPS, geographic coverage, industry risk appetite, currencies, trade finance, technology, team language, cut-off and willingness to serve the applicant’s country are compared.
- CIPS role
- Direct participant, indirect routing and clearing services available
- Risk appetite
- Country, license type, customer segments and industries
- Network
- Branches, correspondent network and coverage of Chinese counterparties
- Operations
- Cut-off, repair process, investigations, returns and reconciliation
- Commercials
- Opening, maintenance, payment, FX, investigation and minimum balance fees
05
Institutional due diligence goes deeper than ordinary KYC
Not only the bank’s corporate structure is checked, but also its customer base, AML/CFT governance, transaction monitoring, sanctions control, correspondent relationships, nested activity and the ability to provide information on underlying customers.
Shareholders, UBO, government participation, group and related financial institutions.
Board, senior management, compliance, MLRO and defense lines.
License, regulator, ratings, audit, capital and enforcement history.
Clients, products, geography, currencies, volumes and purpose of account.
06
AML/CFT and sanctions determine the viability of the project
- AML framework
- Risk assessment, CDD/EDD, UBO, PEP and source-of-funds controls
- Monitoring
- Scenarios, thresholds, alerts, investigations and SAR/STR process
- Sanctions
- Applicable lists, screening, ownership rules and escalation
- Correspondent risk
- Nested relationships, payable-through access and downstream institutions
- Data response
- Time and quality of response to RFI for a client and a specific payment
- Audit
- Independent testing, remediation and confirmation of effectiveness
Will the foreign bank be able to quickly and provably explain who is behind the payment, what its economic purpose is and why the transaction complies with the license and account profile.
07
CIPS indirect participation is not just another account
The candidate selects a CIPS direct participant, is verified and instructed to submit registration. According to official requirements, a legal institution, RMB settlement capability, working business, compliance, risk and system management, as well as a good reputation are required. After registration, a CIPS code is created.
- Indirect participant
- Works through a direct participant and does not open its own current account with CIPS
- CIPS code
- Uniquely identifies the participant and helps determine the payment route
- Direct participant review
- The correspondent checks the application and is responsible for relationship management
- CIPS registration
- The system accepts, requests additions or refuses registration
- Direct participation
- Separate high threshold for business volume, technology, risk and compliance
08
Technical readiness is checked before launch
The operating model includes messaging, BIC and CIPS identifiers, RMA if applicable, payment format, testing, reconciliation, liquidity, cut-off, business continuity and cyber controls. The connection format depends on the correspondent’s product and participant status.
- Messaging
- CIPS/SWIFT connectivity and supported message formats
- Static data
- BIC, CIPS code, correspondents, accounts and routing instructions
- Controls
- Maker-checker, entitlements, limits and privileged access
- Operations
- Repair, reject, return, recall, investigation and statement reconciliation
- Resilience
- BCP, DR, cyber incident response and backup channels
09
Tariffs are calculated together with liquidity
A cheap payment fee may be insignificant compared to the minimum balance, prefunding, FX spread, investigation fees and the cost of idle liquidity. The commercial offer is modeled on real traffic.
- Fixed
- Onboarding, account maintenance, connectivity and participation
- Transactional
- Incoming, outgoing, repair, return, investigation and statements
- FX
- Spread, value date, limits and available currencies
- Liquidity
- Prefunding, overdraft prohibition, credit line and intraday needs
- Volume
- Tier pricing and minimum turnover obligations
10
Process of opening a correspondent account
- 01Qualification
License, country, product, RMB flows and model eligibility.
- 02Bank mapping
Shortlist of Chinese direct participants and correspondents on risk appetite.
- 03Pre-application
Institutional profile, traffic data and preliminary position of the bank.
- 04Due diligence
Corporate, regulatory, financial, AML, sanctions and technology package.
- 05Agreement
Account, RMB settlement, CIPS, pricing, data and operational terms.
- 06Testing & launch
Connectivity, users, routes, liquidity, pilot payments and monitoring.
11
Package of documents of the applicant bank
- 01
Certificate of incorporation, charter, banking license and regulator confirmation.
- 02
Ownership chart, UBO or public/government ownership evidence and group structure.
- 03
Board, management, authorized signatories and account opening resolutions.
- 04
Audited financial statements, capital ratios, ratings and regulatory reports.
- 05
AML questionnaire, policies, enterprise risk assessment and independent audit.
- 06
Sanctions, PEP, transaction monitoring, correspondent banking and RFI procedures.
- 07
Customer base, products, countries, RMB volumes and sample payment flows.
- 08
Technology, information security, BCP/DR and connectivity description.
12
After opening, ongoing monitoring begins
The correspondent regularly updates KYC and compares real traffic with the declared profile. A change in license, ownership, management, countries, products, enforcement or significant incident is reported without waiting for the next review.
- Periodic review
- Updating corporate, regulatory, financial and AML information
- Transaction review
- Volume, countries, clients, assignments and deviations from the profile
- RFI
- Timely response with underlying documents
- Material change
- Immediate notification of events affecting risk
- Exit planning
- Balance, pending payments, data retention and alternative route
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