Why is it so important for the CEOs of the Big Four banks to also serve as Chief Compliance Officers to uphold compliance bottom lines?

Why Has the Role of the AI · Bank President Also Serving as Chief Compliance Officer Become Industry Standard?

The one-year transition period for the “Regulations on Compliance Management of Financial Institutions” has officially ended. The five major state-owned banks—Industrial and Commercial Bank, Agricultural Bank, Bank of China, China Construction Bank, and Bank of Communications—have all confirmed their Chief Compliance Officer appointments. Additionally, joint-stock banks such as Industrial Bank, Ping An Bank, and Shanghai Pudong Development Bank, as well as regional banks like Hangzhou Bank, Nanjing Bank, and Ningbo Bank, have also appointed their Chief Compliance Officers. Based on the announced appointments, “high-level” configurations are a prominent feature among these banks.

This nationwide hiring surge across various banking institutions is directly driven by regulatory constraints. A banking industry insider believes that regulators set strict deadlines to compel banks to complete foundational compliance governance actions in organizational structure and staffing, laying a solid foundation for subsequent, deeper compliance internal controls. From rigid regulatory requirements to personnel adjustments within banks, compliance management is advancing at an unprecedented speed and intensity, shifting from “soft requirements” to “hard constraints.”

The Rise of the Chief Compliance Officer Hiring Wave

In December 2024, the Financial Regulatory Authority issued the “Regulations on Compliance Management of Financial Institutions,” explicitly requiring that “financial institutions shall establish a Chief Compliance Officer at their headquarters. The Chief Compliance Officer is a senior management position, directly reporting to the institution’s Chairman and President (General Manager), and responsible to the Board of Directors.” The regulation takes effect on March 1, 2025, with a one-year transition period. Institutions that do not comply must complete rectification within this period.

This means that March 1, 2026, becomes a hard compliance deadline for all banks. Currently, the banking industry’s wave of appointing Chief Compliance Officers is underway. Since the beginning of this year, the five major state-owned banks—Industrial and Commercial Bank, Agricultural Bank, Bank of China, China Construction Bank, and Bank of Communications—have all announced appointments. However, Postal Savings Bank has yet to release an appointment notice.

On February 13, the Agricultural Bank’s board approved the appointment of President Wang Zhiheng as Chief Compliance Officer; on the same day, the Bank of China’s board approved President Zhang Hui as Chief Compliance Officer. On February 27, China Construction Bank announced that President Zhang Yi would serve as Chief Compliance Officer; on the same day, the Bank of Communications’ board approved Chief Risk Officer Liu Jianjun as Chief Compliance Officer. On March 27, ICBC’s board decided to appoint President Liu Jun as Chief Compliance Officer.

Not only the major state-owned banks but also joint-stock and regional banks are establishing Chief Compliance Officers. Banks such as Industrial Bank, Ping An Bank, Shanghai Pudong Development Bank, Huaxia Bank, and Bohai Bank, as well as regional banks like Nanjing Bank, Hangzhou Bank, Xiamen Bank, and Ningbo Bank, have all confirmed their Chief Compliance Officer appointments.

Dual Roles and High-Level Appointments Are the Mainstream

Among the five major state-owned banks, four—ICBC, Agricultural Bank, Bank of China, and China Construction Bank—have adopted a model where the President personally takes the lead. In joint-stock banks, institutions like China Everbright Bank, Industrial Bank, and China Minsheng Bank often have vice presidents concurrently serving in this role.

In regional banks, such as Nanjing Bank, Jiangsu Bank, and Changshu Bank, the President also serves as Chief Compliance Officer. Specifically, in December 2025, Nanjing Bank announced that the board approved Zhu Gang as Chief Compliance Officer. Zhu Gang is the Deputy Party Secretary, President, and CFO of Nanjing Bank.

Additionally, some banks like Bank of Communications and Shanghai Pudong Development Bank have the Chief Risk Officer and Chief Compliance Officer held by the same person. For example, Shanghai Pudong Development Bank announced on January 1 that the board approved Cui Bingwen as Vice President; Cui also serves as the bank’s Chief Risk Officer, Chief Compliance Officer, and General Counsel.

“Chief Compliance Officers often focus on overseeing the bank’s compliance bottom line regarding national regulatory policies. They hold significant influence within the senior management system and often possess veto power on many issues. Regulators not only require each bank to have a Chief Compliance Officer but also mandate that provincial branches establish compliance officers,” an official from Everbright Bank told reporters.

In fact, the high-level standard has been supported by institutional groundwork. The “Regulations on Compliance Management of Financial Institutions” clearly states that financial institutions can establish a Chief Compliance Officer and compliance officers separately based on their operational needs, or have senior management personnel, provincial branches, or first-level branch managers serve as compliance officers. When the bank’s President (General Manager) serves as the Chief Compliance Officer, or provincial/first-level branch managers serve as compliance officers, no additional licensing or qualification approval is required.

Improving the Compliance Management System

“It is essential to fully leverage the core functions of the Chief Compliance Officer and compliance officers in transmitting, coordinating, and communicating compliance management internally and externally, and to promote compliance work in a coordinated manner. Strengthen the primary responsibility of business lines, the management responsibility of compliance departments, and the supervisory role of internal audit, ensuring organic coordination and effective linkage,” said a regulator.

The Financial Regulatory Authority states that measures should be improved to ensure the performance of duties by Chief Compliance Officers, compliance officers, and compliance management departments and personnel. Financial institutions are required to equip compliance departments with sufficient, professional compliance staff to enhance the effectiveness of compliance management through their expertise. The rights to participate in meetings, be informed, investigate, question, and issue early warnings for Chief Compliance Officers and compliance officers must be clarified. Relevant administrative penalties and other regulatory measures should be strictly enforced against financial institutions and their staff—especially directors, senior managers, Chief Compliance Officers, and compliance officers—who fail to effectively implement compliance management, with increased penalties. Moving forward, efforts will continue to guide financial institutions in improving compliance mechanisms, strengthening operational discipline, and enhancing compliance management quality, thereby promoting high-quality development of the financial industry within the rule of law.