货币跨境流动的反洗钱监管——基于跨境电子收付报告的视角

跨境电子收付报告能够为货币跨境流动的反洗钱监管提供理想的解决方案。跨境电子收付报告的类型化分析和差异性分析,能够满足金融监管部门对货币跨境流动的反洗钱监管需求,也可以为司法部门打击跨境经济犯罪提供高效的侦查、取证方式。本文认为,目前我国构建跨境电子收付报告制度的最大阻力来自于成本因素,但是可以通过实行批量文件处理、坚持最小信息量原则以及设立触发机制来解决,从而有效提高我国货币跨境流动的反洗钱监管效率。

The Anti-money Laundering Regulation to Cross-border Currency Flows:Perspective Based on the Cross-border Electronic Receipt and Payment Report

The cross-border electronic receipt and payment report can provide an ideal solution for the anti-money laundering regulation to cross-border currency flows.Study on typology and difference of cross-border electronic report can provide effective help for the judiciary agencies in the field of investigation and evidence collection when combating cross-border economic crime.It also meets the requirements of financial regulatory authorities on the AML regulation to cross-border currency flows.In this paper,we believe that the biggest obstacle to build the cross-border electronic receipt and payment reporting system in China is the factor of cost,while that issue can be resolved by introducing a series of measures,such as batch file processing,adherence to the minimum amount of information principle,and the establishment of the trigger mechanism.The implementation of those measures can improve the efficiency of AML regulation to cross-border currency flows in China effectively.