Two banks, announced on the same day! The trend of presidents also serving as Chief Compliance Officers is becoming mainstream, with intensive "fill-in" appointments before the transition period concludes.

The Financial Daily Reporter | Liu Jukai The Financial Daily Editor | Huang Bowen

In late February 2026, the banking industry’s compliance governance sector will undergo a series of intensive personnel adjustments. Following the Agricultural Bank of China and Bank of China, Zheshang Bank and Lanzhou Bank announced on the evening of February 27 that their presidents will also serve concurrently as Chief Compliance Officers.

This top-down, comprehensive “fill-in” initiative across various banking institutions is driven directly by the upcoming end of a transition period for a new regulatory rule.

According to the “Regulations on Compliance Management of Financial Institutions” (hereinafter referred to as the “Regulations”) issued by the China Banking and Insurance Regulatory Commission at the end of 2024, financial institutions must establish a Chief Compliance Officer by March 1, 2026.

“The deadline is approaching,” and a sprint to position the core compliance roles is underway. Behind this is the banking industry’s profound shift from “formal compliance” to “substantive governance” in compliance management.

Countdown to Transition, the “Fill-in” of Chief Compliance Officers Enters Final Stage

In December 2024, the China Banking and Insurance Regulatory Commission officially released the Regulations, clearly requiring financial institutions to establish a Chief Compliance Officer at their headquarters, who must be a senior management member directly reporting to the chairman and president (general manager), and accountable to the board of directors. The regulation took effect on March 1, 2025, with a one-year transition period. Institutions failing to comply must complete rectification within this period.

As the February 2026 deadline approaches, the effort to appoint Chief Compliance Officers in the banking sector has entered its “final sprint.” Public information shows that since December 2025, over 20 banks and branches have obtained regulatory approval for relevant appointments. In just December 2025 alone, institutions such as Ping An Bank, Industrial Bank, Minsheng Bank, Nanjing Bank, Jiangyin Bank, and Ruifeng Bank announced the appointment of their Chief Compliance Officers.

In 2026, this trend is accelerating further. On February 10, Suzhou Bank approved the president Wang Qiang to also serve as Chief Compliance Officer; on February 11, Everbright Bank announced Yang Wenhua as Vice President and Chief Compliance Officer; Shanghai Bank also confirmed Shi Hongmin as Chief Compliance Officer; on February 13, Agricultural Bank of China announced President Wang Zhiheng would serve as Chief Compliance Officer, and Bank of China announced President Zhang Hui would do the same. Additionally, Chongqing Bank, Qilu Bank, and Zhangjiagang Rural Commercial Bank have recently completed related personnel procedures.

A senior banking industry analyst pointed out that this wave of appointments is distinctly policy-driven, reflecting regulators’ determination to promote the “standardization” of compliance governance systems. By setting strict deadlines, regulators aim to compel all financial institutions to complete foundational compliance organizational and personnel arrangements, laying a solid groundwork for deeper internal compliance controls in the future.

This move aligns with the ongoing tightening of regulatory penalties. Data from the Enterprise Warning System shows that in 2025, the banking sector received a total of 6,521 fines, amounting to 2.641 billion yuan, a 44.95% increase from 2024. Issues such as credit violations, internal control failures, and anti-money laundering are prominent. In the context of normalized strict regulation, establishing a Chief Compliance Officer is no longer just a formal requirement but an internal necessity for institutions to proactively strengthen risk management and ensure stable operations.

Presidents as Mainstream, “High-Level” Appointments Reflect Efficiency and Checks

Examining the announced appointments reveals a notable trend toward “high-level” placements, especially with presidents or vice presidents of core management concurrently serving as Chief Compliance Officers. Besides Agricultural Bank of China, Bank of China, Zheshang Bank, and Lanzhou Bank, where the bank president directly holds the role, Minsheng Bank and Industrial Bank have vice presidents in this position, and Ping An Bank assigns the role to an assistant president overseeing risk. At city and rural commercial banks, institutions like Nanjing Bank, Jiangyin Bank, and Changshu Bank also commonly adopt the president-as-CCO model.

This “high-level” approach is supported by provisions in the Regulations. Article 14 states that financial institutions may establish a Chief Compliance Officer and compliance officers based on their operational needs, and these roles can be held by senior management, provincial branches, or primary branch managers.

Crucially, the Regulations provide an exemption for the president or branch head serving as Chief Compliance Officer—such individuals are not subject to the usual qualification requirements for compliance roles and do not need separate licensing.

The analyst explained that appointing presidents as Chief Compliance Officers reflects regulators’ emphasis on “substance over form” in compliance management. Traditionally, compliance departments are viewed as cost centers with limited influence within organizations, making it difficult to effectively check business violations. Having the CEO or top decision-maker also serve as compliance head can align compliance with strategic business development, break down departmental barriers, and embed compliance deeply into business processes.

Practically, this model enhances the authority of compliance decision-making and improves governance efficiency. The Chief Compliance Officer is responsible for overseeing the entire compliance system, involving cross-departmental coordination and resource allocation. As the CEO holds the overall management power, their leadership can strengthen the voice of compliance initiatives. In the “executive-involved” model, compliance directives can be directly communicated to front-line units, avoiding hierarchical delays and improving response speed. For example, some banks implement “branch presidents as compliance officers” at the branch level, valuing their quick decision-making and responsiveness.

However, this approach also raises concerns about potential conflicts of roles. The CEO’s primary responsibilities are business growth and profitability, while the compliance head’s role is oversight and checks—potentially creating inherent tensions.

The analyst noted that the current widespread use of the president-as-CCO model is a balancing act between policy compliance, management efficiency, and corporate governance realities. The ultimate success depends on clear delineation of responsibilities and reporting lines to ensure compliance functions operate independently and effectively in practice.

From Position Setup to Governance Deepening: How Can Compliance Truly Create Value

The widespread establishment of the Chief Compliance Officer role marks a new phase in banking compliance management, but its significance extends beyond simply adding an executive position. The deeper challenge is how to translate this institutional arrangement from “paper” to “practice,” shifting compliance from passive regulatory response to active value creation.

According to the Regulations, the Chief Compliance Officer bears significant responsibilities, including leading the compliance management system, promoting its construction, and conducting compliance reviews of major strategies, decisions, and new businesses. This means the role should be a “guardian” of business development rather than an obstacle. Experts emphasize that effective compliance management adds value not only by reducing fines and reputational damage but also by proactively identifying and mitigating risks, fundamentally lowering credit, operational, and other risks caused by non-compliance, thus serving as a “ballast” for stable banking operations.

This role transformation demands higher-quality talent. The Regulations specify strict qualification criteria, emphasizing “financial experience + legal and compliance background.” Facing talent competition, banks are diversifying their recruitment paths: large banks tend to promote internally from experienced risk or business managers, while some smaller banks turn to market-based hiring, even prioritizing candidates with judicial system backgrounds, with corresponding salary levels rising accordingly.

Looking ahead, as personnel arrangements are largely finalized, the banking industry’s compliance governance will enter a “deep water zone.” The next focus will be on the actual operation of mechanisms and cultivating a compliance culture. This includes ensuring the Chief Compliance Officer has sufficient resources and authority, establishing smooth communication and reporting channels, and transforming compliance awareness from top-level advocacy into a conscious behavior across all staff. Only when compliance becomes part of the bank’s “muscle memory” and a source of competitive advantage can the profound value of this institutional reform fully emerge.

(Edited by Qian Xiaorui)

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