Payments and Licensing Lawyers in China

A payment-licensing analysis should follow the complete user and funds journey rather than rely on labels such as marketplace, wallet, collection, settlement or technology service. The file should identify who receives the payment instruction, opens or controls accounts, possesses or transfers funds, determines settlement, handles reserves or prepaid value, bears refund and chargeback duties, and contracts with the payer, merchant, bank and licensed payment institution. Counsel can then test whether the model requires a non-bank payment licence or bank partnership, which licensed business scope applies, and how customer due diligence, anti-money-laundering, safeguarding, reconciliation, cybersecurity, personal information, outsourcing, cross-border payment, pricing, consumer protection, complaints, incidents and exit must operate.

Questions that change the route

How does each instruction and unit of money move?

Diagram onboarding, account or wallet, payment initiation, authentication, acquiring, collection, clearing, settlement, split payment, reserve or prepaid balance, refunds, reversals and chargebacks; identify legal title, custody, bank accounts, cut-off times, currencies, domestic and cross-border legs and every intermediary.

Which entity performs each regulated and customer-facing role?

Map payer, payee, platform, merchant, China operating company, licensed institution, acquiring and settlement banks, card or network, processor and vendors; compare contracts, app screens, invoices and actual operations; verify licence, approved business type, territory, outsourcing and material-change requirements.

Can control records reconcile users, transactions, funds, and risk?

Test identity and merchant due diligence, beneficial ownership, sanctions and anti-money-laundering monitoring, fraud and account controls, safeguarding and reserve arrangements, daily reconciliation, limits, fees, disclosures, complaints, privacy, data localization or transfer, security, business continuity, incident reporting, audit and orderly termination.

Evidence to organize first

• Entity, licence, partner and responsibility matrix; user and merchant journey; instruction, data and funds-flow diagrams; product rules, contracts, screens, disclosures, fee table, account terms and cross-border structure
• Customer and merchant due-diligence files, identity and beneficial-owner checks, monitoring scenarios and alerts, transaction and ledger records, bank statements, safeguarding and reserve evidence, reconciliation, exceptions, refunds, reversals, chargebacks and settlement reports
• Technology and vendor architecture, access and security controls, personal-information assessment, outsourcing due diligence, audit and regulator communications, complaints, fraud and incident files, recovery tests, change approvals, licence reporting and exit or customer-funds return plan

Official orientation sources: Regulation on Supervision and Administration of Non-bank Payment Institutions · Implementing Rules for the Non-bank Payment Institution Regulation · Personal Information Protection Law overview. Source check: 8 October 2026.