Compliance Checklist for Cross border Financial Services Following CRS and Offshore Trust Regulations

In the past few years, many families and businesses have the impression of "opening accounts and releasing money first" when arranging cross-border finance. But since 2026, several things have come together, making it difficult to continue this mindset.

In July 2026, the State Council's Regulations on Outbound Investment officially came into effect, and outbound investment by enterprises was included in a more systematic regulatory framework. Almost at the same time, the Ministry of Finance and the State Administration of Taxation issued a notice on personal income tax for offshore trusts, clarifying that individuals who put their property into offshore trusts and obtain income through offshore trusts need to declare and pay personal income tax in accordance with regulations. On the other hand, CRS information exchange continues to advance in Hong Kong and other places, and the transparency of cross-border accounts and assets continues to improve. Several things point in the same direction: cross-border financial arrangements are transitioning from the era of information asymmetry to the era of compliance and transparency.

For families and businesses, this is not bad news - it means a clearer path to compliance; But it also means that the spaces that relied on fuzzy zones in the past are closing.

1、 Four unavoidable nodes for families to arrange cross-border funds

The first node is the overseas account. Whether it's paying for their child's study abroad, buying a house overseas, or managing their finances overseas, families need a compliant cross-border account. There are significant differences in the requirements for the identity of the account holder, proof of funding sources, and tax residency status among different countries and banks. Before opening an account, it is important to clarify what materials you will be required to provide. The second node is the capital outflow path. There is an annual facilitation quota for personal foreign exchange purchases, but the purpose cannot be used for capital projects that have not yet been opened up, such as buying houses overseas or investing in securities; Large and long-term funding arrangements require a compliant corporate path or specialized channel, and cannot be simply separated. The third node is tax residency status. Obtaining a certain country's identity, residing in a certain country for a certain number of days, or owning property in a certain country may all affect the determination of tax residency and subsequently impact global income declaration. The fourth node is the long-term inheritance arrangement. Family trusts and insurance fund trusts that high net worth families are starting to consider need to be truthfully declared and built in compliance under the new regulations, and cannot be based on "hidden holdings" anymore.

These four nodes strung together form a compliance checklist for cross-border finance in households.

2、 On the enterprise side, there must be a path for funds to go out and come back

Corresponding to the family is the enterprise end. After the implementation of the new regulations on foreign investment in 2026, there are clearer rules for enterprise ODI filing, fund outflow, profit repatriation, and structure construction. When going global, companies need to think about three things at the same time: how to legally export investment funds, how to legally return overseas profits, and how to pay taxes when exiting in the future. These three matters correspond to ODI filing, cross-border tax arrangements, and company structure design respectively. If one link is missing, the rest may get stuck.

The financial arrangements of many enterprises and families are actually interconnected: enterprises set up companies overseas, and individual shareholders open accounts, buy houses, and carry on family inheritance overseas. Separating the compliance of the enterprise end and the household end can easily lead to situations where one side is compliant while the other side is overlooked. This is also why cross-border financial services are shifting from "doing it alone" to "integrating enterprises and families".

3、 Why does this matter require on-site consultation with a professional

The rules of cross-border finance change rapidly and are highly dependent on specific cases. The same 'overseas account opening' has completely different requirements and paths for young people who have just started working, study abroad families, business owners, and high net worth families. Online articles can explain frameworks, but not 'what should I do in my situation'.

The Overseas Immigration, Study Abroad, Real Estate, Enterprise Going Global and Financial Services Expo will be held at the Shanghai World Trade Exhibition Center from November 20 to 22, 2026. The cross-border financial services sector brings together cross-border banks, wealth management institutions, tax law firms, law firms, trust and insurance service providers. A family or business can do several things on site: first consult with the bank about the account opening requirements and material lists for different identities, then confirm their current tax residency status and future arrangements with a tax advisor, then inquire with trust or insurance institutions about the feasible path for building a compliant family structure, and finally align the company's funding path for going global with ODI service providers. About 8000 people are expected to arrive in three days, covering a complete spectrum from small family study abroad payments to large cross-border investments by enterprises.

For financial and professional service institutions participating in the exhibition, the clients they come into contact with on site are mostly enterprises and families who already have real cross-border arrangement needs, and the depth of communication and conversion quality are higher than general traffic.

4、 A compliance first starting list

If households or businesses are preparing to make cross-border financial arrangements, it is recommended to start in this order. The first step is to clarify your current situation: in which countries do you have identity, accounts, assets, and companies. Step two, write down your goals for the next three to five years: how much will your child spend on studying abroad, how much will your company invest in going abroad, and how much will be arranged for family inheritance. The third step is to consult a professional with these two tables instead of listening to a certain institution's product promotion first. Step four, all arrangements require the other party to provide written compliance evidence and do not accept verbal commitments. The fifth step is to conduct a compliance review once a year, as rules and personal circumstances can change.

Cross border finance is not a one-time transaction, it is more like a compliance file that needs to be maintained for a long time. Putting it in a transparent and compliant framework is actually the most worry free approach in the long run.

Exhibition Information: 2026 Shanghai Overseas Immigration, Study Abroad, Real Estate and Enterprise Going Global and Financial Services Expo, November 20-22, 2026, Shanghai World Trade Exhibition Center, lasting for three days, with an expected attendance of about 8000 people. Cross border financial services, ODI enterprises going global, overseas immigration, study abroad, real estate, immigration real estate and other sectors will be opened at the same time. Exhibition hotline: 13681692751 (same as WeChat), official website: www.qs-expo.com.