Effective October 2017, the Shanghai Branch of the PRC State Administration of Foreign Exchange (SAFE) is requiring companies that maintain, or plan to maintain, dedicated foreign exchange accounts with Bank of China, Citibank or HSBC to submit registration applications under Circular 7 (including initial registrations, annual re-registrations, amendment registration and de-registrations) to their bank, rather than directly to Shanghai SAFE.

If your company maintains or plans to file a SAFE registration in Shanghai, read our September 2017 client alert for more information and next steps.