Shanghai Branch of the China Insurance Regulatory Commission (“CIRC Shanghai Branch”) recently released Administrative Measures of the China (Shanghai) Pilot Free Trade Zone for the Record-Filing of Insurance Institutions and Senior Management Personnel(“Measures”). As stipulated in the Measures, if senior management personnel who hold positions in the insurance institutions within the China (Shanghai) Pilot Free Trade Zone (“FTZ”) are assigned to positions of insurance institutions outside the FTZ, they are still required to apply for post-holding qualifications in accordance with relevant provisions of the CIRC on administrative licensing. Where the senior management personnel who hold positions in the insurance institutions within FTZ are assigned to senior management positions of branch of the same insurance institution within the FTZ, they shall report it to the CIRC Shanghai Branch, with separate record-filing formalities exempted from.

KWM Comments: The financial regulatory policy applicable in Shanghai FTZ often keeps its eyes on both transactions within the FTZ and the border-crossing ones. And employers should pay close attention to these features in their human resource management.