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          Wang Zheng: China's procuratorial practice in anti-money laundering

          www.ca-pgc.org | Updated: 2025-12-15 16:25
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          Dear colleagues and friends,

          I am Wang Zheng from the Shanghai People's Procuratorate. It's a pleasure to share with you on the topic of "China's Procuratorial Practice in Anti-money Laundering Work".

          Money laundering crimes seriously endanger national financial security, economic order and social stability, and they also pose a common challenge to the international community. In recent years, China's procuratorial organs have placed the fight against money laundering within the broader context of safeguarding national financial security. Through sustained efforts, we have developed a procuratorial approach with Chinese characteristics.

          I. The Role of Procuratorial Organs in Anti-money Laundering

          In response to the new and complex challenges, China has continuously strengthened its anti-money laundering efforts and improved the relevant legal framework. On January 1, 2025, the newly revised Anti-money Laundering Law came into effect. In August 2024 and August 2025, the Supreme People's Court and the Supreme People's Procuratorate issued judicial interpretations on money laundering and on the crimes of concealing or disguising criminal proceeds. These documents align with international standards and emphasize precise enforcement, providing a solid legal foundation for procuratorial organs to combat money laundering crimes. As state organs for legal supervision and judicial bodies responsible for ensuring the unified and correct implementation of the law, China's procuratorial organs, as one of the key institutions in China's anti-money laundering system, play an important role in fighting money laundering crimes and maintaining financial order. Specifically, our responsibilities include: First, leading criminal prosecution, reviewing and approving arrests, initiating prosecutions, and ensuring that money laundering crimes are punished in accordance with the law. Second, supervising criminal procedures, overseeing case filing, investigation, trial and execution to ensure unified and correct application of the law. Third, promoting social governance, by issuing procuratorial suggestions to address risks and vulnerabilities concerning anti-money laundering identified during case handling. Fourth, engaging in international cooperation, facilitating cross-border investigation, evidence collection and other judicial assistance under international conventions and bilateral agreements.

          II. Measures and Achievements of Procuratorial Organs in Anti-money Laundering

          Since the Chinese government launched a special campaign against money laundering, procuratorial organs across the country have taken strict action against both money laundering crimes and the predicate crimes in accordance with the law. We have continuously improved the legal system, strengthened preventive mechanisms through collaboration, and enhanced international cooperation and achieved positive progress and results.

          First, handling each case with high quality and efficiency. Handling money laundering cases in line with international standards is a cornerstone of our procuratorial work. We maintain a high-pressure stance, implement the "one case with parallel investigation" mechanism, pursuing both the predicate crime and the laundering activity, and pay special attention to third-party money laundering and emerging channels such as virtual assets and underground banking. The Supreme People's Procuratorate has released two batches of typical money laundering cases to strengthen guidance and raise public awareness. Taking the Shanghai People's Procuratorate as an example, to support Shanghai's development as an international financial center, we established comprehensive financial prosecution bases in the Bund and Lujiazui. There, we successfully handled several landmark cases, such as the nation's first cross-border money laundering case involving virtual currency and the nation's first case involving live-streaming donations, turning every case into a showcase of China's rule of law. Through research on typical cases, we issued annual white papers on financial prosecution and reports on money laundering, drafted practical guidelines for handling foreign-related cases, and therefore established the Shanghai procuratorial model of "case handling—research—reports—rules".

          Second, building and improving a collaborative mechanism. Anti-money laundering work requires extensive coordination. Internally, anti-money laundering spans multiple areas, including finance, cybercrime, corruption and drug trafficking, etc. In addition to criminal prosecution departments handling ordinary crimes, major crimes, duty-related crimes and economic crimes, it also involves various departments from legal policy research to case management and international cooperation. The Supreme People's Procuratorate and provincial-level procuratorates have established anti-money laundering work leading groups to improve coordination. Through coordinated efforts, the effectiveness of collaboration has been maximized, and the positive outcome has been included in the annual work reports of the Supreme People's Procuratorate. Externally, anti-money laundering work involves legislation, law enforcement, judiciary, diplomacy and other aspects, which requires collaboration with relevant departments to achieve full-chain cooperation from financial intelligence to investigation, prosecution, trial and governance, as well as jointly promote international judicial cooperation in cross-border evidence collection, fugitive repatriation, asset recovery and intelligence sharing. Under the guidance of the inter-ministerial mechanism on anti-money laundering, procuratorial organs, as one of the members, have actively participated in the three-year campaign to combat money laundering crimes since 2022. From 2022 to 2024, the average annual number of people prosecuted for money laundering crimes is four times that of 2021. In terms of collaborative mechanisms, local procuratorial organs have explored and innovated based on local circumstances. For example, in Beijing, the procuratorate and the local branch of People's Bank of China set up a joint office where prosecutors work side-by-side with financial experts, and both sides leverage their respective advantages, and facilitate case investigation, clue discovery and outcome evaluation.

          Third, leveraging new technologies. With the development of internet and other technologies, money laundering cases involve increasingly larger fund scales and more complex fund flows, posing new challenges to the review and determination of money laundering crimes. We embrace technological changes, strengthen empowerment in the digital era, and jointly promote the use of modern technological means such as big data and AI to enhance the tracking of involved funds and improve the investigation, control and recovery of them. Another example is the case handled by Shanghai prosecutors involving Wu and three others for fund-raising fraud and money laundering. Using technology from the "Project on Electronic Data Review of Funds in Financial Crime Prosecution", which is co-developed with the research institutions, prosecutors conducted big data analysis on more than 180 involved bank accounts during the review of the predicate crimes and identified over 20 additional related accounts. By tracking and cross-referencing, the amount of money laundering funds involved was increased largely, clues of self-money laundering crimes were discovered, leading to two new prosecutions affirmed by the court.

          III. Future Prospects of Procuratorial Work in Anti-money Laundering

          Anti-money laundering is crucial for China's high-quality development and its role in global financial governance. Moving forward, we will promote the in-depth development of anti-money laundering work through high-quality and efficient procuratorial performance. First, closely monitor new trends in money laundering and maintain a strict enforcement stance against money laundering activities, and actively integrating into the broader collaborative framework of anti-money laundering work. Second, ensuring handling each case with high-quality and efficiency, adhering to the "one case with parallel investigation" mechanism, actively responding to new and complex money laundering cases, and fully leveraging the role of typical cases. Third, deeply promoting international judicial cooperation in combating cross-border crimes, actively preparing for the FATF's fifth round of anti-money laundering evaluation, demonstrating the image of a responsible major country on the international stage, sharing China's anti-money laundering stories, and contributing Chinese solutions to global anti-money laundering efforts.

          Thank you.

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