CHINA’S EFFORTS TO EXPAND

THE INTERNATIONAL USE OF THE RENMINBI

Eswar S. Prasad

February 4, 2016
1

Report prepared for the 

U.S.-China Economic and Security Review Commission

CHINA’S EFFORTS TO EXPAND

THE INTERNATIONAL USE OF THE RENMINBI

Eswar Prasad1

February 4, 2016

Disclaimer: This research report was prepared at the request of the U.S.-China Economic and Security 

Review Commission to support its deliberations. Posting of the report to the Commission's website is 

intended to promote greater public understanding of the issues addressed by the Commission in its 

ongoing assessment of U.S.-China economic relations and their implications for U.S. security, as 

mandated by Public Law 106-398 and Public Law 108-7. However, it does not necessarily imply an 

endorsement by the Commission or any individual Commissioner of the views or conclusions expressed 

in this commissioned research report.

Disclaimer: The Brookings Institution is a private non-profit organization. Its mission is to conduct highquality, independent research and, based on that research, to provide innovative, practical 

recommendations for policymakers and the public. The conclusions and recommendations of any 

Brookings publication are solely those of its author(s), and do not reflect the views of the Institution, its 

management, or its other scholars.

 1 Cornell University, Brookings Institution, and NBER. The author is grateful to members and staff of the 

Commission for their thoughtful and constructive comments on an earlier draft of this report. Audrey 

Breitwieser, Karim Foda, and Tao Wang provided excellent research assistance. William Barnett and 

Christina Golubski provided editorial assistance. The opinions expressed in this report are solely those of 

the author and do not reflect the opinions of the institutions with which the author is affiliated.
2

Table of Contents

Executive Summary........................................................................................................................ 3

1. Introduction and Overview ......................................................................................................... 6

2. Capital Account Opening............................................................................................................ 9

3. The Exchange Rate Regime...................................................................................................... 27

4. China’s Domestic Financial Markets........................................................................................ 39

5. International Use of the RMB................................................................................................... 55

6. The RMB’s Role as a Reserve Currency .................................................................................. 72

7. Implications of the RMB’s Inclusion in the IMF’S SDR Basket ............................................. 82

8. Sequencing and Transitional Risks........................................................................................... 90

9. The RMB’s Impact on the World ............................................................................................. 98

10. Conclusion ............................................................................................................................ 105

Appendix A: Capital Account Categories in the AREAER........................................................ 106

Appendix B: Selected Developments Pertaining to Capital Account Policies and RMB 

Internationalization, 2004–2015 ................................................................................................. 108

Appendix C: Restrictions on Investment in the FTZs ................................................................ 128

References................................................................................................................................... 134
3

Executive Summary

This report analyzes three related but distinct aspects of the renminbi’s (RMB) role in the global 

monetary system and describes the Chinese government’s actions in each of these areas:

• Internationalization: Its use in denominating and settling cross-border trade and financial 

transactions, that is, its use as an international medium of exchange.

• Capital account convertibility: The country’s level of restrictions on inflows and 

outflows of financial capital. 

• Reserve currency: Whether the RMB is held by foreign central banks as protection 

against balance of payments crises. 

China is promoting the international use of its currency by:

• Permitting the settlement of trade transactions with the RMB. In 2015, trade settlement in 

RMB amounted to about $1.7 trillion, roughly one quarter of China’s annual trade 

volume. 

• Allowing issuance of RMB-denominated bonds in Hong Kong (with an outstanding stock 

of bonds worth nearly $400 billion in 2015) and other financial centers.

• Permitting selected banks to offer offshore RMB deposit accounts.

• Setting up 15 offshore RMB clearing centers, including in Frankfurt, Paris, and London.

• Creating a payment system for easier settlement of cross-border RMB transactions. 

These steps are gaining traction, although they are still modest in scale. The RMB is the fifthmost important payment currency but still accounts for less than 3 percent of worldwide 

payments for cross-border trade and financial transactions. The RMB also accounts for less than 

2 percent of turnover in global foreign exchange markets. 

Starting in 2000, China resisted appreciation pressures on the RMB by intervening in foreign 

exchange markets to prevent its value from rising rapidly relative to the U.S. dollar. This move 

led to the accumulation of nearly $4 trillion in foreign exchange reserves by June 2014. The 

RMB began facing mild depreciation pressures in the summer of 2014, and China has 

experienced a surge in capital outflows since then. Despite an ostensible move to a marketdetermined exchange rate in August 2015, the currency’s value relative to the dollar continues to 

be managed by the People’s Bank of China (PBC). By the end of 2015, China’s reserves had 

fallen to $3.3 trillion as the PBC tried to limit the RMB’s depreciation relative to the dollar. 

The RMB’s prospects as a reserve currency will be influenced by these criteria:

• Economic size: A country’s size and its shares of global trade and finance are important 

determinants of reserve currency status. China accounts for 13 percent of world gross 

domestic product (16 percent if measured by purchasing power parity rather than market 

exchange rates) and 11 percent of world trade in goods. 

• Macroeconomic policies: Investors in a country’s sovereign assets must have faith in its 

commitment to low inflation and sustainable levels of public debt. China has a lower 

ratio of explicit public debt to GDP than most major reserve currency economies and has 

maintained moderate inflation in recent years. 
4

• Open capital account: The currency must be easily tradable in global financial markets 

with no restrictions on capital flows. China is gradually and selectively easing restrictions 

on both inflows and outflows. The capital account has become increasingly open in de 

facto terms, but there are still extensive capital controls in place. 

• Flexible exchange rate: Reserve currencies trade freely, and their external value is market 

determined. China has increased the flexibility of its exchange rate, although the central 

bank still intervenes in foreign exchange markets to keep the value of the RMB stable 

relative to the dollar. The exchange rate will become increasingly harder to manage as the 

capital account becomes more open. 

• Financial market development: A country must have well-developed financial markets 

and provide international investors with access to a wide array of financial assets 

denominated in its currency. China has relatively shallow government and corporate bond 

markets, with low trading volumes, and a volatile stock market. 

The RMB is already on the path to being a reserve currency both in principle and in practice:

• The RMB’s inclusion in the basket of currencies that make up the IMF’s Special Drawing 

Rights, with a weight of 10.9 percent, makes it an official reserve currency. 

• A number of central banks are holding, or have announced plans to hold, at least a small 

fraction of their foreign exchange reserve portfolios in RMB-denominated assets. It is 

estimated that about one percent of global foreign exchange reserves is in RMB assets.

• The PBC has set up currency swap arrangements with 34 central banks.

China faces two major domestic challenges that will influence the RMB’s role in the global 

monetary system and also determine the balance and sustainability of China’s growth: 

• Sequencing of capital account opening with other policies, such as exchange rate 

flexibility and financial market development: Freeing up cross-border capital flows before 

strengthening domestic financial markets and letting the currency float freely could affect 

capital flow volatility and pose risks to financial stability. 

• Financial market development: Measures such as strengthening the banking system and

developing more stable and well-regulated equity and bond markets are important for 

better resource allocation within China.

Recent turmoil in Chinese equity and currency markets suggests that financial market reforms, in 

the absence of broader market-oriented and institutional reforms, could generate volatility with 

few corresponding benefits. Reforms to the real side of the economy, including state-owned 

enterprise reform and liberalization of the services sector, are important adjuncts to financial 

market and capital account reforms. Institutional reforms such as better corporate governance, 

enhanced auditing and accounting standards, and stronger regulatory frameworks are also 

required. China’s slowing growth momentum could complicate, or even stall, these much-needed 

reforms. In the absence of broad reforms, inefficient resource allocation, lower productivity 

growth, and wasteful investment will persist. This would drag down growth, worsen the debt 

overhang, and heighten risks to the financial system. The recent tightening of capital controls to 

limit capital outflows and RMB depreciation could hurt investor confidence and impede the 

process of RMB internationalization.
5

The main forward-looking conclusions of the report are as follows:

• China’s capital account is likely to become largely open within the next three to five 

years, with few restrictions on capital inflows and outflows other than some “soft” 

controls related to registration and reporting requirements. 

• The RMB will play an increasingly important role in global trade and finance, with the 

currency being used more widely to denominate and settle cross-border transactions. 

• The underdeveloped state of China’s financial markets is likely to be the major constraint 

on the RMB’s rising prominence in international finance. 

• The present leadership’s commitment to financial sector and other market-oriented 

reforms—if implemented effectively and with careful management of transitional risks—

sets the RMB on a clear course to become a significant reserve currency. 

The implications for the United States are as follows:

• The structure of capital flows from China to the United States will shift from official 

purchases of U.S. Treasury securities to other channels—including foreign direct 

investment and debt/equity portfolio flows—as portfolio diversification by Chinese 

households, corporations, and institutional investors begins dominating China’s capital 

outflows. 

• The RMB’s growing prominence as an international currency will, over time, diminish 

the dollar’s role as a unit of account (for denominating international trade transactions) 

and a medium of exchange (for settling cross-border financial transactions).

• Although the RMB is on track to become a significant reserve currency, a broader set of 

political, legal, and institutional reforms are required for the RMB to become a safehaven currency. In the absence of these broader reforms, the rise of the RMB will erode 

but not seriously challenge the dollar’s status as the dominant global reserve currency.
6

1. Introduction and Overview

China’s economy is now the second largest in the world and a key driver of global growth. Its 

currency, the renminbi (RMB), was only recently elevated to the status of an official reserve 

currency. The potential for the RMB to develop quickly into an international currency is not 

without historical precedent.2 However, any discussion of the RMB’s ascendance might seem 

premature given that China has neither a flexible exchange rate nor an open capital account, once 

considered essential prerequisites for a country’s currency to have a major role in global 

financial markets.

This report outlines some of the steps taken in recent years by the Chinese government to 

promote the international use of the RMB, which in turn is linked to moves to open up China’s 

capital account. Given China’s rising shares of global GDP and trade, these steps are gaining 

traction and portend a rising role for the RMB in global trade and finance. The report then 

reviews the potential implications of these changes for capital flows into and out of China. The 

report evaluates the progress that China has made in various aspects of financial market 

development and discusses the close relationship between those reforms, capital account 

openness, and the international role of the currency. It also discusses the prospects for the RMB

becoming a reserve currency and the implications that could have for the global configuration of 

reserve currencies and the U.S. economy. 

The Chinese government’s approach to policies that promote the RMB’s use as an international 

currency is closely linked to domestic macroeconomic objectives and financial market 

development. The RMB’s impact on the global monetary system—in particular whether it will 

contribute positively to global financial stability—depends on the manner and speed with which 

China opens up its capital account and develops its financial markets as well as on the other 

policy changes put in place to support this process and the implications for China’s own growth 

and stability. 

This report analyzes three aspects of the RMB’s role in the international monetary system: (i) the 

trajectory of the RMB’s “internationalization”; (ii) the likelihood and timing of China’s path to 

currency convertibility (an open capital account with no restrictions on capital inflows or 

outflows); and (iii) the prospects of the RMB becoming a major reserve currency. 

The report will evaluate these three related but distinct elements within a unified conceptual 

framework and evaluate their implications along two dimensions: first, by reference to the 

balance and sustainability of China’s own economic development; and second, by reference to 

the associated implications for the global monetary system, including for the U.S. dollar’s status 

as the dominant reserve currency.

 2 The speed of the dollar’s ascent as it vaulted past the pound sterling is documented by Eichengreen and 

Flandreau (2009).
7

1.1. Concepts

There is a great deal of hyperbole surrounding the RMB, with some commentators going so far 

as to argue that its displacement of the dollar as the dominant reserve currency is imminent.3

Before evaluating these claims, it is important to first clarify a few relevant concepts. Popular 

discussions of the RMB’s emergence on the international stage tend to conflate three related but 

distinct aspects of a currency’s role in international finance. 

• Internationalization: Its use in denominating and settling cross-border trade and financial 

transactions, that is, its use as an international medium of exchange.

• Capital account convertibility: The country’s level of restrictions on inflows and 

outflows of financial capital. A fully open capital account has no restrictions on crossborder capital flows. 

• Reserve currency: Whether the currency is held by foreign central banks as protection 

against balance of payments crises. 

The international usage and convertibility of a currency are distinct concepts, and neither is a 

necessary or sufficient condition for the other. The RMB is a prime example of a currency that is 

increasingly being used in international transactions even though China restricts capital flows. 

And of course there are many countries that have fully open capital accounts but whose 

currencies do not have broad acceptance in global markets. Some economies have a fully open 

capital account but a fixed exchange rate. For instance, Hong Kong has an open capital account 

but lacks a flexible exchange rate, as the Hong Kong dollar is pegged to the U.S. dollar. 

All of these conditions—capital account convertibility, floating exchange rate, and 

internationalization—have been regarded as necessary for a currency to become a reserve 

currency. This report will consider how much progress China has made along each of these 

dimensions and describe how they are interconnected. 

The typical prerequisites for a reserve currency are as follows:

• Economic size: A country’s GDP as well as its shares of global trade and finance are 

important, although not crucial, determinants of its reserve currency status.

• Macroeconomic policies: Investors in a country’s sovereign assets must have faith in its 

economic policies, especially the commitment to low inflation and sustainable levels of 

public debt, so the value of the currency is not in danger of being eroded. 

• Open capital account: Reserves must be acceptable as payments to a country’s trade and 

financial partners, which requires that the currency be easily tradable in global financial 

markets. 

 3 Prasad and Ye (2012) provide a systematic evaluation of China’s progress along each of the dimensions 

of the RMB’s progress as an international currency. Chen, Peng, and Shu (2009) and Subramanian (2011) 

argue that the RMB is well on its way to becoming a major, if not dominant, reserve currency. Dobson 

and Masson (2009), Eichengreen (2011b), and Kroeber (2011) offer more nuanced and skeptical views. 

Angeloni et al. (2011) discuss probabilities of alternative scenarios, noting that the RMB may gain 

prominence if the euro does not mount a serious challenge to the dominance of the U.S. dollar.
8

• Flexible exchange rate: Reserve currencies are typically traded freely and their external 

value is market determined, although this does not preclude occasional bouts of 

intervention by the country’s central bank in foreign exchange markets. It is worth 

emphasizing that an open capital account is not synonymous with a freely floating 

exchange rate.

• Financial market development: A country needs to have a broad range of wellfunctioning financial markets, especially government bond markets, to provide a 

sufficient quantity of high-quality financial assets that can be held by foreign investors,

including central banks. The amount of trading (turnover) in these bond markets, which 

determines how easy it is for investors to get into or out of these investments, is also 

important. 

This report will provide a quantitative evaluation of China’s progress on each of these metrics. In 

addressing these criteria vis-à-vis the RMB, this report will discuss two major challenges China 

faces:

• Sequencing of capital account opening with other policies, such as exchange rate 

flexibility and financial market development, to improve the benefit/cost trade-off

• Financial market development—strengthening the banking system; developing extensive 

and well-regulated government and corporate bond markets as well as foreign exchange 

spot and derivative markets

Financial market development in the home country is one of the crucial determinants of a 

currency’s international status. The relevant aspects of financial market development include:

• Breadth: the availability of a broad range of financial instruments, including markets for 

hedging risk;

• Depth: a large volume of financial instruments in specific markets 

• Liquidity: a high level of turnover (trading volume)

Without a sufficiently large debt market, the RMB cannot be credibly used in international 

transactions. If there is insufficient liquidity in equity and fixed-income (government and 

corporate debt) markets for RMB-denominated assets, the currency will not be attractive to 

foreign investors, especially institutional investors and central banks. At the same time, both 

importers and exporters may be concerned about greater exchange rate volatility resulting from 

an open capital account if they do not have access to derivatives markets to hedge foreign 

exchange risk. 

This report evaluates China’s financial market development and reforms (both actual and 

proposed), as these are crucial for the RMB’s prospects as a reserve currency. The report also 

evaluates the potential impact of the rise of the RMB on the U.S. economy and financial markets 

as well as on the U.S. dollar. 
9

2. Capital Account Opening

This chapter provides documentation and an assessment of China’s capital account openness in 

both de jure and de facto terms.4 It also provides some analytical perspectives on China’s 

approach to capital account liberalization.

The first question is, why would capital account liberalization be a priority for China given the 

many domestic challenges the economy faces, including slowing economic growth, a weak 

financial system, and unbalanced growth that is still heavily dependent on investment? It may be 

that liberalization of outflows would generate a number of collateral (indirect) benefits for the 

domestic economy, particularly in terms of domestic financial market development that, in turn, 

could facilitate more stable growth.

5

Liberalizing outflows provides Chinese households with opportunities to diversify their savings 

portfolios internationally and stimulates domestic financial reforms by creating competition for 

domestic banks that currently depend on captive domestic sources of funds (retail deposits of 

households and corporations). Initiatives to encourage corporate outflows have focused on large 

state-owned firms and a concentrated set of sectors such as natural resources.6 For the RMB to 

take on a more international role, both portfolio and foreign direct investment (FDI) outflows

will need to involve more participation from the private sector.

The liberalization of inflows is also an important part of the overall picture in terms of attaining 

the collateral benefits of capital account liberalization.7 This liberalization already has allowed 

and will continue to allow foreign investors to play a larger role in further developing and 

deepening China’s financial markets. For instance, there is a significant body of evidence that 

liberalizing portfolio inflows helps improve liquidity in the domestic equity markets of emerging 

economies. This, along with the entry of foreign banks, would increase competition in the 

banking sector, which in turn would benefit private savers and borrowers. Other segments of 

China’s financial sector, including the insurance sector, have depended on capital controls and 

other entry restrictions to stay competitive. These segments will face greater competition with 

more open inflows. With effective regulation, this could lead to significant efficiency gains. 

Capital account liberalization could also have broader benefits for China. An open capital 

account would catalyze progress toward the objective of making Shanghai an international 

financial center. Capital account opening, especially if accompanied by greater exchange rate 

flexibility, could also strengthen China’s domestic economic structure. It would facilitate 

financial sector reforms, allowing for a rebalancing of growth away from a reliance on exports 

and investment-driven growth to a more balanced model of growth with higher private 

consumption. Financial sector reforms can play a crucial role in this rebalancing effort by 

 4

A burgeoning body of literature on specific aspects of China’s exchange rate management and capital 

account liberalization includes Frankel (2005, 2011), Eichengreen (2011b), Lardy and Douglass (2011), 

Yam (2011), and Yu (2011, 2015).

5 See Prasad and Rajan (2008).

6 See Rosen and Hanemann (2009) and Scissors (2011). 

7 See Kose, Prasad, Rogoff, and Wei (2009) for an analytical discussion and a survey of the evidence to 

support the arguments in this paragraph. 
10

promoting a more efficient allocation of resources towards the most productive uses. A more 

flexible exchange rate would free up monetary policy to facilitate achieving domestic 

macroeconomic objectives such as maintaining low and stable inflation.8

2.1. De Jure Capital Account Openness

De jure measures of capital account openness typically rely on binary indicators from the 

International Monetary Fund (IMF)’s Annual Report on Exchange Arrangements and Exchange 

Restrictions (AREAER). These binary measures reflect the existence of any restrictions on a 

large number of categories of inflows and outflows. These measures change only when there is a 

relatively major policy shift related to specific capital account items. The AREAER indicates 

that, as of 2014, China had restrictions of some sort in 14 out of 15 categories of capital inflows 

and in 15 out of 16 categories of capital outflows. These categories, which are listed in Appendix 

A, are quite broad. The only ones China does not restrict are inflows and outflows of commercial 

credit. By contrast, the United States and most other advanced economies have almost entirely 

open capital accounts.

Other conventional measures of de jure financial openness drawing on the AREAER data show 

little, if any, change for China over the past decade. For example, the popular Chinn-Ito index 

(Chinn and Ito, 2008, and subsequent updates) has registered very little change in China’s de jure 

openness since 1993. The index, which is based on a statistical procedure that aggregates 

information from various categories covered by the AREAER, ranges from 2.39 (most 

financially open) to -1.89 (least financially open). A higher value corresponds to a greater degree 

of de jure capital account openness. 

The advanced economies with reserve currencies (such as Canada, Japan, Switzerland, the 

United Kingdom, and the United States.) have the same index value of 2.39, which is the 

maximum and indicates a fully open capital account. The value of this index for China in 2013 is 

-1.19, compared with an average close to the maximum for advanced economies, 0.3 for 

emerging market economies, and 0.1 for less developed economies. This value indicates a 

relatively closed capital account characterized by capital controls that are, on paper, extensive 

and stringent. China’s index jumped from -1.89 to -1.19 in 1993 and has not changed at all since 

then. 

Standard de jure indices fail to capture many subtle or limited changes in capital account 

openness, changes that tend to be aggregated across categories of inflows or outflows. Appendix 

B provides detailed documentation of significant changes to capital account restrictions during 

the past decade, based on the AREAER reports. The listing indicates that the number and 

magnitude of relaxations to capital account restrictions have gathered pace in the past few years, 

consistent with the active promotion of the RMB as an international currency. In most cases, 

constraints on inflows and outflows have been made less stringent rather than eliminated 

entirely. 

 8 See Prasad (2009) for a more detailed discussion of these issues. 
11

2.2. De Facto Openness

An alternative and complementary approach to evaluating an economy’s financial openness is to 

analyze de facto measures of integration into global financial markets. Figure 2-1 shows the 

levels of China’s gross external (foreign) assets and liabilities, along with the net asset position, 

from 2004 through the first quarter of 2015. China now has $6.4 trillion of external assets and $5 

trillion of external liabilities. Both assets and liabilities have risen sharply over the last decade.

Figure 2-1. China’s External Assets and Liabilities

(in trillions of U.S. dollars)

Source: State Administration of Foreign Exchange via CEIC

Figure 2-2 shows that China’s gross external assets comprise roughly 62 percent of GDP while 

gross external liabilities equal about 44 percent of GDP in 2014. A standard measure of financial 

openness used widely in the academic literature is an economy’s gross assets plus liabilities 

position (i.e., its gross external position) either in levels or as a ratio to GDP.9 For China, the 

ratio of gross assets and liabilities to GDP is now over 100 percent. In terms of levels, China’s 

gross external position exceeds those of other key emerging markets and also that of Switzerland 

As a share of GDP, its openness lags behind those of the reserve currency economies. Among 

emerging markets, however, China’s de facto measure of openness is relatively high, exceeding 

the levels of countries such as Brazil and India.10

 9 See Kose, Prasad, Rogoff, and Wei (2009). 

10 See Prasad and Ye (2012). 

-6	

-4	

-2	

0	

2	

4	

6	

8	

2004	 2005	 2006	 2007	 2008	 2009	 2010	 2011	 2012	 2013	 2014	 2015Q1	

Assets	 Liabilities	 Net	Assets	
12

Figure 2-2. China’s External Assets and Liabilities

(in percent of GDP)

Source: State Administration of Foreign Exchange via CEIC

Starting in 2015, China began reporting its international investment position (IIP) based on the 

IMF’s latest Balance of Payments and International Investment Position Manual (BPM6). A 

major change, according to the State Administration of Foreign Exchange (SAFE), is that the key 

IIP items are now reported using the market capitalization method rather than the historical flow 

accumulation method. Data through 2014 are still reported based on BPM5. Hence, comparisons 

of the IIP in 2015 with those of prior years are not feasible. It should be noted that SAFE began 

reporting balance of payments data based on BPM6 standards earlier, so those data are in fact 

comparable over time, although these changes also highlight the difficulty of matching flow and 

stock measures in earlier years.

An examination of China’s IIP in 2015 (at the end of the second half of the year) reveals a 

number of interesting features (Table 2-1). Foreign exchange reserves account for 58 percent of 

China’s external assets. FDI accounts for 57 percent of China’s external liabilities, while 

portfolio equity liabilities account for another 14 percent. Portfolio debt and other investments 

(which typically capture bank loans) account for 29 percent of external liabilities. The relatively 

low share of external debt in China’s external liabilities, coupled with the fact that foreign 

exchange reserves are more than sufficient to cover them, suggests that China is not exposed to 

the vulnerability caused by high levels of external debt that has precipitated past crises in many 

emerging market economies. 

-60	

-40	

-20	

0	

20	

40	

60	

80	

100	

2004	 2005	 2006	 2007	 2008	 2009	 2010	 2011	 2012	 2013	 2014	

Assets	 Liabilities	 Net	Assets	
13

Table 2-1. China’s International Investment Position

(in billions of U.S. dollars)

Source: SAFE via CEIC

To summarize the evidence from de facto and de jure measures of openness, China still has an 

extensive capital control regime in place, but it is selectively and cautiously dismantling these 

controls. Many of the restrictions on cross-border capital flows have been loosened over time, 

consistent with the policy objective of promoting the RMB’s role as an international currency. In 

most cases, constraints on capital inflows and outflows have been loosened but not eliminated. 

The country’s capital account is becoming increasingly open in de facto terms, although by this 

measure China is financially less open than many reserve currency economies. 

2.3. Controlled Capital Account Liberalization

China’s government has created a number of schemes that allow for controlled and calibrated 

opening of the capital account to both inflows and outflows. These schemes have been designed 

to generate many of the collateral benefits of financial openness while creating freer movement 

of capital. Table 2-2 contains a summary of the main schemes that have recently been instituted 

to liberalize inflows, outflows, and two-way flows. A more detailed description of each of these 

programs follows after the table.11

 11The exchange rate used to calculate U.S. dollar equivalents of RMB data in this table and the remainder 

of this report is based on the January 4, 2016 exchange rate of RMB 6.5 per U.S. dollar. 

2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015H1

Net position 276 408 640 1188 1494 1491 1688 1688 1866 1996 1776 1471

Assets 929 1223 1690 2416 2957 3437 4119 4735 5213 5986 6409 6430

FDI 53 64 91 116 186 246 317 425 532 660 744 1013

Portfolio 92 117 265 285 253 243 257 204 241 259 263 276

Equity 0 0 1 20 21 55 63 86 130 153 161 178

Debt 92 117 264 265 231 188 194 118 111 105 101 98

Other investments 166 216 254 468 552 495 630 850 1053 1187 1503 1370

Reserve Assets 619 826 1081 1547 1966 2453 2914 3256 3388 3880 3899 3771

FX Reserves 610 819 1066 1528 1946 2399 2847 3181 3312 3821 3843 3694

Liabilities 653 816 1050 1228 1463 1946 2431 3046 3347 3990 4632 4959

FDI 369 472 614 704 916 1315 1570 1907 2068 2331 2678 2827

Portfolio 57 77 121 147 168 190 224 249 336 387 514 900

Equity 43 64 106 129 151 175 206 211 262 298 369 673

Debt 13 13 14 18 17 15 18 37 74 89 145 227

Other investments 227 267 315 378 380 442 637 891 943 1272 1440 1232
14

Table 2-2. A Summary of Recent Schemes to Liberalize Cross-Border Capital Flows

Channels for Inflows

Qualified Foreign Institutional Investor (QFII) Scheme: Launched in 2002. Allows qualified 

foreign institutions to convert foreign currency into RMB and invest in Chinese equities (both A 

shares and B shares) and a range of other RMB-denominated financial instruments. As of 

October 2015, a total quota of $78.9 billion had been granted to 277 foreign institutions, 

including 8 central banks and 10 sovereign wealth funds. 

Renminbi Qualified Foreign Institutional Investor (RQFII) Scheme: Launched in 2011. Allows 

qualified institutions to use offshore RMB funds to invest in Chinese equities and a range of 

other RMB-denominated financial instruments. As of July 2015, a total quota of $68.4 billion 

had been granted to 135 financial institutions.

Channels for Outflows

Qualified Domestic Institutional Investor (QDII) Scheme: Launched in 2006. Allows Chinese 

domestic financial institutions—commercial banks, securities companies, fund management 

companies, and insurance companies—to invest in offshore financial products such as securities 

and bonds. As of November 2015, a total quota of $90 billion had been granted to 132 financial 

institutions. 

Qualified Domestic Individual Investor (QDII2) Scheme: Proposed in 2013; not yet launched. 

Will permit individual retail investors with at least RMB 1 million ($160,000) in assets to invest 

in offshore financial products such as securities and bonds. 

Channels for Two-Way Flows

Free Trade Zones (FTZs): Shanghai FTZ launched in September 2013. Three new FTZs in 

Guangdong, Tianjin, and Fujian launched in April 2015. The FTZs use a “negative list” approach 

to regulate foreign investment—there are few restrictions on foreign investment in industries not 

on the list. Cross-border capital transactions and establishment of financial institutions within the 

zones have been liberalized. 

Shanghai-Hong Kong Stock Connect: Launched in 2014. Allows mainland Chinese investors to 

purchase shares of select Hong Kong and Chinese companies listed in Hong Kong, and lets 

foreigners buy Chinese A shares listed in Shanghai. HK-to-Shanghai annual quota: RMB 300 

billion ($47 billion); daily quota RMB 13 billion ($2 billion). Shanghai-to-HK annual quota: 

RMB 250 billion ($39 billion); daily quota: RMB 10.5 billion ($1.6 billion). 

Mutual Fund Connect: Launched in July 2015. Allows eligible mainland and Hong Kong funds 

to be distributed in each other’s markets through a streamlined vetting process. Initial aggregate 

investment quota: RMB 300 billion ($47 billion) each for inward and outward fund flows.

Sources: SAFE, China Securities Regulatory Commission.
15

Channels for Inflows

Qualified Foreign Institutional Investor (QFII) Scheme

The QFII scheme, introduced in December 2002, allows qualified foreign institutional investors 

(FIIs) to convert foreign currency into RMB and invest in A shares listed on the Shanghai and 

Shenzhen stock exchanges as well as in other RMB-denominated financial products approved by 

the China Securities Regulatory Commission (CSRC).12 The scheme seeks to attract high-quality 

and stable (medium-to-long-term) foreign portfolio investments while deterring short-term 

speculative inflows of foreign capital. One of the scheme’s main objectives is to promote the 

development of China’s securities market. 

CSRC and the SAFE share regulatory authority over China’s QFII Scheme. CSRC has 

responsibility for approving license applications, and SAFE sets the investment quota. CSRC and 

SAFE have established eligibility criteria for QFII applicants with the explicit goal of blocking 

short-term, speculative capital inflows of foreign capital and inviting long-term investors such as 

pension, insurance, mutual, and charitable funds that have long-term investment horizons. FIIs

applying for QFII status are required to meet minimum eligibility criteria related to the number 

of years of operation, the dollar value of total assets under management (AUM), and sound 

financial status and corporate governance. They also need to be domiciled in countries with 

sound legal and regulatory systems and whose securities market regulators have entered into a 

memorandum of understanding (MOU) for maintaining regulatory cooperation with the CSRC. 

QFIIs are typically foreign fund management institutions, insurance companies, securities 

companies, and other asset management institutions that have been granted a license by the 

CSRC and an investment quota by SAFE to invest in China’s financial market and, most 

importantly, in the A share market. QFII eligibility criteria related to the minimum number of

years of operation and the minimum total AUM in the most recent fiscal year have been 

progressively liberalized to allow an increasing number of foreign institutional investors—

smaller and lesser known—to undertake portfolio investment in China. 

SAFE has, over time, liberalized the flows of foreign portfolio investment via the QFII channel 

by increasing the aggregate amount available for allocation as QFII quotas and also by relaxing 

the maximum quotas for individual QFIIs. As of October 2015, the total investment quota 

awarded under the scheme was about $78.9 billion, covering 277 institutions. CSRC also 

announced that it intends to raise the total QFII quota from $80 billion to $150 billion. 

SAFE has also gradually increased the maximum amount that each QFII can be granted in 

quotas. For the period from January 2003 to September 2009, each QFII could be granted a 

maximum amount of $800 million across all quota allocations. In late 2009, this maximum was 

increased to $1 billion. Only a handful of sovereign wealth funds, central banks, and monetary 

authorities were allowed to invest more than $1 billion. In March 2015, the $1 billion investment 

 12 This sub-section draws on Sharma (2015). Before 2002, the A share market was closed to foreign 

investors.
16

quota limit for overseas fund management companies was lifted as part of the effort to further 

open up the country’s capital market and pursue structural reforms.

QFIIs from advanced and industrial economies remain predominant with only 10 of the 251 

QFIIs (i.e., less than 5 percent) being domiciled in emerging and developing markets. The

highest number of QFIIs (45, or 18 percent) is domiciled in Hong Kong followed by the United 

States (38, or 15 percent) and the United Kingdom (27, or 11 percent). It is estimated that QFIIs 

hold, on average, two-thirds of their total assets in China in the form of A shares.

13 However, 

QFII investments in the A share market remain small compared with the overall size of that 

market. A shares held by QFIIs account for less than 2 percent of the tradable capitalization of 

the A share market. Thus, any effects of the QFII scheme on securities markets development 

have been largely catalytic rather than directly substantive in nature. 

In the early stages of the program, each QFII was required to hold no less than 50 percent of its 

total assets in equities or equity-related instruments and no more than 20 percent of its assets in 

cash. These restrictions sought to avert the expectation that QFIIs were likely to place the bulk of 

their assets in fixed-income securities and even cash, mainly to speculate on RMB appreciation. 

Since 2012, the CSRC has eliminated the restriction that a minimum of 50 percent of a QFII’s 

investment portfolio has to be held in equity or equity-related instruments. However, QFIIs still 

cannot hold more than 20 percent of their investment portfolio in cash. Moreover, investments by 

a QFII in any single company listed in China cannot exceed 10 percent of its total shares, and the 

cumulative shares held by all QFIIs in any single company cannot exceed 20 percent of its total 

shares.14

RMB Qualified Foreign Institutional Investor (RQFII) Scheme15

The RQFII program was jointly launched in late 2011 by CSRC, SAFE, and the PBC. The key

difference between the QFII and the RQFIIs programs is that RQFIIs can use offshore RMB to

invest in mainland markets directly. By contrast, QFIIs must first convert their foreign currency

funds into RMB before purchasing equities and securities in onshore markets. Thus, the RQFII

scheme may be seen as a response of Chinese government authorities to the expansion of the

pool of offshore RMB funds. This scheme, like the QFII scheme, requires financial institutions

to apply for licenses from CSRC and investment quotas from SAFE, and to submit all relevant

materials to the PBC. Approved institutions need to open special RMB accounts separately for

investment on foreign exchange markets, interbank bond markets, and stock index futures in

 13 See Sharma (2015). 

14 Latest versions of the rules and regulations governing the QFII program can be found on the CSRC 

website at: http://www.csrc.gov.cn/pub/csrc_en/OpeningUp/RelatedPolices/QFII/. 15 This sub-section draws on the following official sources: PBC Notice on “Implementation of the

Measures for Pilot Domestic Securities Investment Made by RMB Qualified Foreign Institutional

Investors” http://bit.ly/1RCfNk0; CSRC Circular on “Measures for Pilot Domestic Securities Investment

Made by RMB Qualified Foreign Institutional Investors of Fund Management Companies and Securities

Companies” http://bit.ly/1TYo7tN; and SAFE Circular on “Relevant Issues Concerning the Pilot Program

on Domestic Securities Investments by Fund Management Companies and Securities Companies as RMB

Qualified Foreign Institutional Investors” http://bit.ly/1ONOMcv. 
17

domestic custodian banks. In addition, the accounts for the institutions’ self-owned funds and the

funds of clients must be separated.

16

The movements of funds under the RQFII scheme are subject to various restrictions. The funds

that can be remitted inward include the investment principal remitted from overseas, amounts

required for the payment of the relevant taxes and fees, and other RMB funds permitted by the

PBC and SAFE to be remitted inward. The funds that can be remitted outward include income

from the sale of domestic securities, cash dividends and interest, and other RMB funds permitted

by the PBC and SAFE to be remitted outward. These funds may be remitted outward in RMB or

in foreign exchange purchased with RMB.

Initially, only Hong Kong subsidiaries of Chinese financial institutions were eligible for RQFII 

licenses. Since 2014, the scheme has been expanded to additional Hong Kong banks and asset 

managers and subsequently also to financial institutions in the United Kingdom, Singapore, 

South Korea, France, Germany, Australia, and Switzerland. As of July 2015, 135 financial 

institutions, including foreign institutions and foreign branches of China’s financial institutions, 

have been granted a total quota of $68.4 billion under this scheme. Financial institutions from 

Hong Kong, many of which are Hong Kong branches of mainland financial institutions, are still 

the major players. Hong Kong now accounts for $43 billion of the allocated RQFII quota and 

South Korea for $8 billion.17 The introduction of RQFII has given rise to several RMBdenominated A share exchange-traded funds (ETFs). RQFII ETFs seek to track the performance 

of an A share index by investing RMB raised outside the mainland directly in a portfolio of A

shares. 

Channels for Outflows

Qualified	Domestic	Institutional	Investor	(QDII)	Scheme18

The QDII scheme allows Chinese domestic financial institutions, most of which are still state 

owned, to invest in offshore financial products such as securities and bonds. The origin of the 

program was the Chinese government’s decision in September 2004 to allow insurance 

companies such as Ping An (Group) to invest assets abroad. The program was officially launched 

in 2006 and permits selected commercial banks, securities companies, fund management 

 16 Notice of the People’s Bank of China on the Implementation of Measures for the Pilot Program of

Securities Investment in China by RQFIIs.

17 The RQFIIs with the top five quota allocations (amounting to roughly a combined $20 billion) are all 

based in Hong Kong—CSOP Asset Management Limited; E-Fund Management (Hong Kong) Co., 

Limited; China Asset Management (HK) Limited; Harvest Global Investments Limited; and Haitong 

International Investments Limited. 

18 This sub-section and the next one draw on the following sources: IMF Statement by Zhou Xiaochuan

Governor, People’s Bank of China,

https://www.imf.org/External/spring/2015/imfc/statement/eng/chn.pdf; “China may let individuals in

Shanghai FTZ invest abroad in H1—Sources” Reuters, April 29. 2015; and “Shanghai trade zone aims for

QDII2 trial this year—Official” Reuters, March 17, 2015.
18

companies, and insurance companies to invest in foreign capital markets subject to certain 

restrictions. 

Financial institutions have to first apply for a QDII license from the relevant regulatory agencies 

(CSRC, China Banking Regulatory Commission, and China Insurance Regulatory Commission), 

which depends on their main line of business. They then have to seek a quota allocation from 

SAFE. The general qualification requirements for QDII include (i) stable financial status and 

good credit; (ii) qualified personnel with the requisite asset management and risk assessment 

expertise; (iii) sound governance structure and internal control systems; and (iv) no record of any 

major penalty levied by the relevant regulatory authority. There are also specific requirements 

depending on the types of institution involved. For example, an eligible fund management 

company needs to have net assets of at least RMB 200 million, at least two years of active 

participation in the fund management business, and more than RMB 20 billion or assets of equal 

value under management at the end of the latest quarter.

The scope of investments under the QDII program is subject to certain restrictions, with 

investments in bank deposits, debt securities, stocks, bonds, and derivatives being permitted, 

while investments in real estate and precious metals are forbidden. The proportions of the 

portfolios of the funds are required to stay consistent with regulatory rules. The approved 

investment destinations for QDIIs include Hong Kong, the United Kingdom, the United States,

Singapore, Japan, Korea, Luxemburg, Germany, Canada, Australia, and Malaysia. It is 

interesting to note that these are mostly advanced economies, and all of them have welldeveloped financial markets and good financial sector regulatory frameworks. 

As of November 2015, 132 institutions have been granted QDII licenses and a total quota of $90

billion has been set. The breakdown of quotas by institution type is as follows: securities

companies ($38 billion), insurance companies ($31 billion), banks ($14 billion), and trust

companies ($8 billion).

Qualified Domestic Individual Investor (QDII2) Scheme

The proposed Qualified Domestic Individual Investor scheme, commonly known as QDII2, will 

expand the QDII scheme from institutional to individual retail investors. The scheme was first 

proposed by the PBC in January 2013 and discussed by the State Council later in May of that 

year. In April 2015, PBC Governor Zhou Xiaochuan confirmed in a speech to the IMF’s 

International and Monetary Finance Committee that China would launch the pilot QDII2. 

However, the scheme has yet to be formally launched. In June 2015, the Shanghai government’s

official website indicated that Shanghai would launch a trial of the program in its free trade zone 

by the end of the year. The plan was also discussed in a report on RMB internationalization 

released by the PBC in June 2015.

19

 19 The relevant documents are as follows: The Report on Internationalization of RMB (PBC, June 2015); 

The Plans on Promoting the Trials of Finance Opening and Innovation in Shanghai FTZ to Accelerate the 

Construction of Shanghai International Financial Center (Co-released by PBC, Ministry of Commerce, 

CBRC , CSRC, CIRC, SAFE and Government of Shanghai, October 2015).
19

The program will eventually be launched in at least six Chinese cities: Shanghai, Tianjin, 

Chongqing, Wuhan, Shenzhen, and Wenzhou. However, the specific framework and timeline of 

the program have yet to be announced. News reports indicate that the new pilot scheme will 

allow individuals with at least RMB 1 million (roughly $160,000) in assets to invest directly 

overseas in securities, stocks, and real estate. At present, the maximum amount of RMB that 

individuals can exchange for foreign currency is subject to an annual cap of $50,000 per year; 

this restriction would not apply to investors under QDII2.

20

2.4. Free Trade Zones 

China has extended its experimental, learning-by-doing approach to reforms to the capital 

account liberalization program. One manifestation of this approach has been in the form of free 

trade zones (FTZs) that are islands of capital account convertibility within China. The objective 

of these zones is to allow for a greater degree of capital account openness but in a controlled 

manner by limiting it to specific geographical areas. 

The China Pilot Free Trade Zone in Shanghai was officially launched on September 29, 2013. It 

was expanded in 2015 to include Lujiazui, the city’s financial district. In late February 2014, the 

PBC and SAFE issued two circulars to loosen controls on foreign exchange transactions and to 

promote cross-border use of the RMB within the Shanghai FTZ. The regulators for the banking, 

securities, and insurance industries (China Banking Regulatory Commission, CSRC, and China 

Insurance Regulatory Commission) all issued circulars announcing measures to open up 

financial services in the FTZ.21

 20 See, for instance, “China to launch QDII2 overseas investment scheme soon in six cities,” Reuters, 

October 26, 2015; and “China to allow individuals buy overseas financial assets,” Financial Times,

October 29, 2015.

21 The relevant links and official documents from which the materials in this section are drawn are as 

follows: State Council Infographic: Negative List on Foreign Investment in China’s Free Trade Zones.

http://english.gov.cn/policies/infographics/2015/04/21/content_281475093149079.htm. Circular of the

Shanghai Headquarters of the People’s Bank of China on Supporting Expanded Cross-Border Use of

RMB in the China (Shanghai) Pilot Free Trade Zone; http://en.china-shftz.gov.cn/Governmentaffairs/Laws/Banking/265.shtml. Circular of the Shanghai Headquarters of the People’s Bank of China on

Supporting Expanded Cross-Border Use of RMB in the China (Shanghai) Pilot Free Trade Zone;

http://en.china-shftz.gov.cn/Government-affairs/Laws/Banking-Regulatory/265.shtml. Notice of Shanghai

Branch of the State Administration of Foreign Exchange on Issuing the Detailed Rules for the

Implementation of Regulations on Foreign Exchange Management in the China (Shanghai) Pilot Free

Trade Zone; http://en.china-shftz.gov.cn/Government-affairs/Laws/General/255.shtml. Circular of the

Shanghai Headquarters of the People’s Bank of China on Lifting the Upper Limit on Small-amount

Foreign Currency Deposit Rates in the China (Shanghai) Pilot Free Trade Zone; http://en.chinashftz.gov.cn/Government-affairs/Laws/Banking/264.shtml. Circular of the China Banking Regulatory

Commission on Issues Concerning Banking Supervision in China (Shanghai) Free Trade Zone;

http://en.china-shftz.gov.cn/Government-affairs/Laws/Banking/191.shtml. Circular of the China

Insurance Regulatory Commission on Supporting the Construction of the China (Shanghai) Pilot Free

Trade Zone. http://en.china-shftz.gov.cn/Government-affairs/Laws/Insurance/193.shtml
20

In April 2015, China launched three new FTZs. Each of these FTZs is expected to cover a few 

specific sectors. Major industries in the Guangzhou Nansha New Area (including the Nansha 

bonded port) include the shipping industry, logistics, the financial industry, international trade, 

and high-end manufacturing. The Shenzhen Qianhai Development Zone will cover the financial 

industry, modern logistics, information services, and technology services. The Zhuhai Hengqin 

New Area will include the tourism industry and finance services as well as cultural, education, 

and high-tech industries.

22

Some of the key features of the FTZs are as follows: (i) without seeking approval from the PBC,

banking institutions in the zone are free to process cross-border RMB settlements under current

accounts and under direct investment for entities; (ii) companies in the zone are allowed to

borrow RMB offshore, although these funds cannot be used outside the FTZ and cannot be

invested in securities or used for extending loans; (iii) voluntary foreign exchange settlement by

foreign-invested enterprises (FIEs) within the zone is permitted, allowing FIEs to convert foreign

currency in their capital accounts into RMB at any time; (iv) qualified foreign-invested banks are

allowed to set up subsidiaries, branches, or special institutions to upgrade existing sub-branches

to branches; (v) qualified private investors can enter the banking sector in the FTZ and set up

banks, finance leasing companies, consumer finance companies, and other finance institutions;

and (vi) the government has indicated its intention to support banking institutions in the FTZ to

develop cross-border financing services.

Despite its name, an FTZ is not fully open to foreign investors. The Shanghai FTZ uses a

“negative list” structure to regulate foreign investment, the first of which the Shanghai

government unveiled in 2013. The implication of the negative list is that investment in sectors

that are not on the list is mostly unrestricted, although some administrative procedures must still

be followed. The approval process for establishing an FIE in an industry not on the negative list

has been simplified.

On April 20, 2015, the State Council issued the third edition of the negative list, which now

applies to all four FTZs. The 2015 negative list contains 122 prohibited or restricted areas, down

from 139 in the 2014 list, although these numbers are not directly comparable over time because

of changes in classifications and definitions. Part C of the Appendix tabulates the main elements

of the negative list and highlights some of the significant changes relative to the previous

versions of the negative list.

Changes include removing certain restrictions in the mining, air traffic control systems

management, medical and pharmaceutical product manufacturing, and telecommunications

industries. A number of restrictions in manufacturing and in retail and wholesale trade have been

lifted. Restrictions on investment in sectors such as real estate, construction, and textiles have

also been removed. Foreign investments are restricted to joint ventures with domestic companies

in sectors such as oil and natural gas exploration and development, general-purpose airplane

design, and rare earths smelting. Sectors in which neither domestic nor foreign companies can

invest, such as weapons and ammunition, are not included in the list.

 22 The discussion in this sub-section draws on some material from China Briefing, an online resource 

provided by Dezan Shira & Associates. 
21

Foreign companies in the FTZs will be subject to a national security review if they seek to invest

in certain “sensitive industries, technologies, and locations.” Under rules effective as of May

2015, foreign companies will have to undergo such a review if they invest and have a controlling

stake in “the military industry, certain agricultural produce, major energy and resources, major

infrastructure projects, and telecommunication products that may affect national security.”

Detailed descriptions of the types of companies that are subject to this review and the structure of

the review process are provided in Appendix C. During President Xi’s visit to the United States

in September 2015, China committed to limiting the scope of the national security review.

However, there are still significant concerns about how this process might impede foreign

investment in the FTZs.23

The FTZs provide a significant channel for two-way capital flows through the banking system as

well as through corporates, although there is in principle a firewall between each FTZ and the

rest of the mainland. Over time, these firewalls are likely to erode since there are multiple

financial institutions and corporations operating on both sides. Nevertheless, using FTZs does

provide the government with another controlled approach to capital account opening that

mitigates the potential risks of full capital account opening.

2.5. The Shanghai–Hong Kong Stock Connect

An alternative approach to selective and calibrated capital account liberalization would be 

implementing a stock connect program that creates another channel for cross-border equity 

investments by a broad range of investors, including retail investors. The “stock connect” link 

between the Shanghai and Hong Kong stock exchanges was officially launched on November 17, 

2014. The program allows mainland Chinese investors to purchase shares of select Hong Kong 

and Chinese companies listed in Hong Kong (Southbound investment), and lets foreigners buy 

Chinese A shares listed in Shanghai (Northbound investment) in a less restrictive manner than 

had previously been the case. Trading in each direction under this program is subject to a 

maximum cross-border investment quota (i.e., an aggregate quota), together with a daily quota. 

The Northbound aggregate quota is set at RMB 300 billion (roughly $45 billion), with the daily 

quota being RMB 13 billion (about $2 billion). The corresponding Southbound quotas are RMB 

250 billion (aggregate, roughly $40 billion) and RMB 10.5 billion (daily, roughly $1.7 billion). 

Compliance with these quotas in each direction is monitored by the Stock Exchange of Hong 

Kong (SEHK) and the Shanghai Stock Exchange.

The quota balances are calculated at the end of each trading day on a net-buy basis: Aggregate

Quota Balance = Aggregate Quota - Aggregate Buy Trades + Aggregate Sell Trades. The daily

 23 White House Office of the Press Secretary, Fact Sheet: U.S.-China Economic Relations, September 25, 

2015. https://www.whitehouse.gov/the-press-office/2015/09/25/fact-sheet-us-china-economic-relations. 

Also see the briefs by Tim Stratford and Yan Luo, “National Security Review Creates FDI Hurdle,” 

China Law & Practice (Covington & Burling), July 13, 2015, 

https://www.cov.com/~/media/files/corporate/publications/2015/07/national_security_review_creates_fdi

_hurdle.pdf; and Thomas Chou et al., “China’s Draft Foreign Investment Law: A Paradigm Shift in 

Regulation of Foreign Investment,” Morrison & Foerster LLP, February 12, 2015. 

http://www.mofo.com/~/media/Files/ClientAlert/2015/02/150212ChinasDraftForeignInvestment.pdf.
22

quota caps the daily net value of cross-border trades and is updated on a real-time basis. When

the balance falls short of the daily quota, all buy orders on the next trading day are suspended

while sell orders are still accepted. The control mechanism under the daily quota can be shown in

the form of the schematic in Table 2-3.

Table 2-3. Control Mechanism for Daily Quotas under the Stock Connect Program

Call Auction Continuous Auction

Balance ≤ Zero

New buy orders will be 

rejected until balance 

reaches positive level

No further buy orders will be 

accepted for this trading day

Sell orders will still be accepted

Source: Shanghai Stock Exchange

Enforcement of the daily and annual quotas is managed through the structure of the settlement

mechanisms. The Hong Kong Securities Clearing Corporation (HKSCC) and the China

Securities Depository and Clearing Corporation (CSDC) in mainland China are each other’s

clearing participants and undertake the settlement obligations of their respective clearing

participants’ trades on a net basis. Importantly, settlement is undertaken on the day after a trade

is executed. In addition, the stock exchanges on both sides keep themselves informed by tracking

buying and selling transactions as well as daily balances. With these mechanisms in place,

regulators have real-time information on the volume of trades in both directions as well as the

quota balances.

This investment channel has been used quite extensively. The Northbound daily quota was met

on the launch day and has been consistently high (until the summer of 2015, when the Chinese

stock market began to fall sharply), while the Southbound daily cap was hit for the first time in

April 2015. The government has indicated that it plans to set up more stock-connect schemes that

link other mainland cities to Hong Kong, but no specific dates have been announced.

2.6. Effects on the Volume and Composition of Capital Flows

In short, while China still has an extensive capital control regime in place, it is selectively and 

cautiously dismantling these controls. Partly as a result of this dismantling, the country’s capital 

account is becoming increasingly open in de facto terms. This trend has affected both the 

volumes and composition of capital inflows and outflows.

Figure 2-3 shows that the volumes of gross capital inflows and outflows (excluding official 

accumulation of foreign exchange reserves) have trended upward since 2000. Gross inflows rose 

from $58 billion in 2000 to a peak of $563 billion in 2013. With rising concerns about China’s 

short-term growth prospects, gross inflows then fell sharply in 2014 and 2015 (to facilitate 

comparison across years, the data on gross flows for 2015 are calculated by simply doubling the 

data for the first half of the year). Gross outflows, by contrast, have remained strong in 2014–

2015. In 2014, gross outflows nearly hit $400 billion, compared with $56 billion in 2000. 
23

Figure 2-3. Gross Capital Inflows and Outflows

(in billions of U.S. dollars)

Source: SAFE via CEIC

Note: Data for 2015 are based on doubling the data for the first half of that year. 

Figure 2-4 shows that the composition of gross inflows has shifted significantly over time. FDI 

has been the key component of inflows in most years since 2000, mainly because the government 

had reduced barriers to FDI inflows but maintained substantial restrictions on other types of 

inflows for most of the previous decade.

24 In 2010 and 2011, bank loans and other investment 

surged as the government opened up other channels for inflows. Portfolio inflows began to pick 

up in 2012 due to the increase in quotas and liberalization of the QFII scheme as well as the 

introduction of the RQFII scheme. However, portfolio inflows still remain modest relative to 

overall inflows. FDI inflows held up well in the first half of 2015, but bank loans and other 

investment in fact reversed course.

25

 24 See Prasad and Wei (2007). 

25 Although this chart shows gross inflows, foreign investors’ repatriation of previous inflows counts as a 

negative item in balance of payments accounting. 

0 

100 

200 

300 

400 

500 

600 

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 

Inflows 

Outflows 
24

Figure 2-4. Composition of Gross Capital Inflows

(in billions of U.S. dollars)

Source: SAFE via CEIC

Figure 2-5 examines the composition of gross capital outflows (other than foreign exchange 

reserve accumulation by the PBC). Starting in 2007, “other investments” have dominated gross 

outflows. From 2008 onward, direct investment outflows have also become large, accounting for 

an average of roughly $60 billion in outflows each year. Portfolio outflows rose significantly in 

the first half of 2015, possibly reflecting the increasing number of channels available for Chinese 

investors to take money out and also the decline in the Chinese stock market (which began in 

June 2015). 

-200 

-100 

0 

100 

200 

300 

400 

500 

600 

700 

800 

Other Inv. 

Bank Loans 

Portfolio Inv. 

Direct Inv. 
25

Figure 2-5. Composition of Gross Capital Outflows

(in billions of U.S. dollars)

Source: SAFE via CEIC

Rising foreign investments by Chinese households, corporations, and institutional investors have 

led to a marked shift in the pattern of China’s overall exports of financial capital, which include 

not only the gross capital flows studied above but also the accumulation of foreign exchange 

reserves. To explore changes in the composition of overall capital outflows, they are split into (i) 

reserve accumulation and (ii) gross private and non-reserve official outflows plus (the negative 

of) net errors and omissions. The latter category includes foreign investments made by the China 

Investment Corporation (China’s sovereign wealth fund) as well as by other state-owned 

financial and corporate entities. Figure 2-6 shows the trailing three-year moving averages of 

shares of gross capital outflows accounted for by these two components. There is clearly a trend 

toward change in the composition of gross outflows, which has shifted markedly from reserve 

accumulation to official and unofficial flows due to both the private and state sectors. This shift 

is consistent with the SAFE’s stated objective of shifting foreign exchange risk from the central 

bank’s balance sheet to those of households, corporations, and state-controlled entities such as 

the sovereign wealth fund. 

The objective of “foreign exchange holdings by the people” (rather than the central bank) will 

have a significant impact on the composition of future capital outflows from China. While the 

government is providing channels for international portfolio diversification, which is a positive 

development, there is a risk that lack of effective oversight of domestic securities markets and 

institutional investors that enable such diversification could portend risks for household and 

corporate balance sheets. 

-50 

0 

50 

100 

150 

200 

250 

300 

350 

400 

450 

Other Inv. 

Bank Loans 

Portfolio Inv. 

Direct Inv. 
26

Figure 2-6. The Structure of China’s Gross Capital Outflows

(in percent)

Sources: SAFE and CEIC 

Notes: This figure shows three-year trailing averages of the shares of China’s gross capital outflows 

accounted for by net reserve accumulation and all other outflows, which includes private outflows as well 

as foreign investments by Chinese official agencies, including its sovereign wealth fund. Data for 2015 

are based on data for the first half of the year.

While the government is taking a number of steps to promote capital account liberalization, its

final objective in this regard remains unclear. The end game for the government appears to be a 

capital account that is largely open but still subject to some degree of administrative control. 

Joseph Yam (2011), the former head of the Hong Kong Monetary Authority, has argued that the 

long-term objective for China ought to be full capital account convertibility, which he defines as 

relaxation of capital controls but maintenance of “soft” controls in the form of registration and 

reporting requirements for regulatory purposes. He draws a careful distinction between this and 

an entirely unfettered capital-flow regime, referred to as free capital account convertibility. This 

is a subtle but important distinction that appears to have resonated well with the Chinese 

leadership, given that full convertibility by this definition provides a path to an open capital 

account without ceding control entirely to market forces. 

0 

25 

50 

75 

100 

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 

Gross private and non-reserve outflows 

Reserve accumulation 
27

3. The Exchange Rate Regime

This chapter describes developments in the exchange rate regime, the evolution of the RMB’s 

value against the U.S. dollar and other currencies, and the structure of the foreign exchange 

trading system. Since the early 2000s, China has been criticized by the United States and 

international institutions such as the IMF for keeping its currency undervalued through foreign 

exchange market intervention. For much of this period, China was running large trade surpluses 

as well as financial account surpluses, reflecting large net capital inflows. To prevent the 

currency appreciation that would result from these twin surpluses, China intervened in foreign 

exchange markets, essentially by recycling foreign currency inflows through purchases of those 

foreign currencies, which were then invested mostly in advanced economy government bonds. 

Although measures of currency undervaluation are notoriously imprecise and unreliable, a clear 

sign of the renminbi’s undervaluation for much of the last decade and a half is the rapid 

accumulation of foreign exchange reserves, which, by June 2014, had reached a peak of $3.99 

trillion.

While analyzing these developments, there are two points worth noting. First, even though China 

has clearly intervened heavily in foreign exchange markets to moderate currency appreciation, 

since 2005 the RMB has appreciated substantially relative to the dollar and the currencies of its 

other trading partners. Second, since the summer of 2014, pressures on the RMB have reversed 

and, in recent months, the PBC has in fact been intervening in the other direction, spending of its 

hard currency reserves to prevent the RMB from depreciating rapidly. Since June 2014, China’s 

foreign exchange reserves have fallen by about 12 percent, to $3.53 trillion in October 2015. 

3.1. Exchange Rate Management 

The value of the RMB had been tightly managed against the U.S. dollar since the mid-1990s, but 

it was allowed to appreciate gradually against the dollar starting in July 2005 (Figure 3-1). In 

principle, starting at that time the PBC implemented a managed floating exchange rate 

mechanism, with the currency’s value determined by market demand and supply, and with 

reference to a basket of currencies. The PBC would announce the reference rate (relative to the 

U.S. dollar) at which the RMB would begin trading each day, with intra-day volatility of plus or 

minus 0.3 percent permitted. In reality, the practice of managing the value of the RMB relative to 

the U.S. dollar did not stop and the amount of daily volatility was quite limited, although over 

time the RMB was allowed to appreciate gradually relative to the dollar.

In May 2007, the daily trading band was widened to 0.5 percent in each direction relative to the 

reference rate. With the U.S. housing market beginning to unravel in late 2007, eventually 

triggering the onset of the global financial crisis in the second half of 2008, the RMB’s hard peg 

to the dollar was reinstituted in July 2008 before being relaxed again in June 2010. In April 

2012, the daily fluctuation band of the RMB-dollar exchange rate was widened to 1 percent on 

either side of the reference rate set by the PBC. In March 2014, the daily fluctuation band was 

widened further to 2 percent on each side. Although the PBC has not allowed the foreign 

exchange market to freely determine the RMB’s value, the RMB has in fact appreciated by about 

35 percent relative to the dollar since June 2005, when it was depegged from the dollar. 
28

Figure 3-1. China: Bilateral Exchange Rates

(RMB per unit of foreign currency)

Source: SAFE

Note: The left scale shows the RMB’s exchange rates relative to the U.S. dollar and the euro. The right 

scale shows the RMB’s exchange rate relative to the Japanese yen. A decrease denotes appreciation of the 

RMB. An increase denotes depreciation.

Despite these moves to ostensibly increase currency flexibility, over the last decade the volatility 

of China’s nominal exchange rate against the dollar, as measured by the standard deviation of 

changes in monthly exchange rates, has been the lowest among the major emerging market 

economies.26 China’s trade-weighted effective exchange rate measures, which tend to track each 

other closely, are more volatile than the nominal exchange rate.27 The gap in exchange rate 

volatility relative to other emerging markets is smaller using these measures, but China still has 

the lowest level of volatility in this group, suggesting a lower level of flexibility than the other 

currencies in this group. In other words, China displays more flexibility in its effective exchange 

rate, but this flexibility is still quite limited. Nevertheless, the RMB has appreciated by 47 

percent on a trade-weighted basis since June 2005 (Figure 3-2). On an inflation-adjusted basis, 

the appreciation over this period is even greater—about 57 percent. 

 26 See Prasad and Ye (2012). 

27 The trade-weighted exchange rate is an index computed as a weighted average of the RMB’s bilateral 

exchange rates with China’s major trading partners, with the weights reflecting the share of each of those 

partners in China’s total foreign trade. This “effective” exchange rate can be computed either on the basis 

of bilateral nominal exchange rates only (the nominal effective exchange rate) or by adjusting for 

differences in the inflation rate between China and those of each of its trading partners (the real effective 

exchange rate). 

0.04	

0.05	

0.06	

0.07	

0.08	

0.09	

5	

6	

7	

8	

9	

10	

11	

12	

RMB	per	yen	

RMB	per	dollar	and	euro	

dollar	 euro	 yen	
29

Figure 3-2. China: Effective Exchange Rates

(June 2005 = 100)

Source: Bank for International Settlements

Note: A decrease denotes appreciation of the RMB. An increase denotes depreciation.

China’s foreign exchange rate management can be characterized as having three elements:

• The reference pricing mechanism, whereby the PBC sets the opening price for trading on 

the Shanghai China Foreign Exchange Trading System (CFETS) each morning.

• A 2 percent trading band around the central parity, which determines the maximum 

amount of intra-day volatility in the RMB–dollar exchange rate.

• A dirty float, to prevent excessive exchange rate fluctuations when the PBC determines 

that the exchange rate is overshooting on one side or the other.

28

On August 11, 2015 the PBC changed the first element of the exchange rate management 

mechanism, combined with a 1.9 percent devaluation of the RMB relative to the dollar. The 

other two elements were left unchanged.29 Until then, the PBC’s opening reference price could 

differ from the closing price on the CFETS the previous trading day. In other words, relative to 

the opening reference price, the RMB could rise by 2 percent or fall by 2 percent during a given 

trading day. But the reference price the next morning could be, and often was, the same as the 

opening reference price on the previous day. With the recent change, that is no longer the case. 

The reference price is no longer delinked from the previous day’s closing price although, with 

 28 This characterization is adapted from remarks made at a conference by PBC chief economist Ma Jun. 

29 PBC Announcement on Improving Quotation of the Central Parity of RMB against US Dollar, August 

11, 2015. http://www.pbc.gov.cn/english/130721/2941603/index.html.

90 

100 

110 

120 

130 

140 

150 

160 

2005 2006 2007 2008 2009 2010 

2011 

2012 2013 2014 2015 

real 

nominal 
30

RMB trading now taking place in markets such as London that are in other time zones, the two 

prices need not necessarily be the same. The key point is that the RMB exchange rate relative to 

the dollar is now more subject to market forces. 

It appeared on August 11 that the PBC had combined a move to weaken the RMB with a shift to 

a more market-determined exchange rate. In principle, this move should have blunted criticism 

that it was merely an orchestrated currency devaluation since all the PBC was doing was 

reducing its foreign exchange market intervention to prop up the RMB’s value as part of a shift 

to a more free-floating currency. China’s currency move could also be interpreted as a relatively 

modest and defensive one, aimed at signaling that the PBC would not persist in supporting the 

RMB’s value relative to the dollar if the dollar were to keep rising against other major currencies. 

Indeed, in the year before this move, the trade-weighted effective exchange rates of the RMB

had appreciated sharply (Figure 3-2).

However, the shift in currency policy set off a negative reaction in financial markets that were 

already jittery because of fears over a sharp slowdown in growth in China and the volatility in 

the Chinese the stock market that had manifested since June 2015. Stock markets around the 

world, including in the United States, fell sharply as China’s policy action was taken as a 

response to domestic economic weakness rather than as a market-oriented reform. The move also 

reverberated in currency markets worldwide as it was interpreted as an indication that China’s 

central bank had joined others such as the European Central Bank and the Bank of Japan in 

trying to engineer a weaker currency in order to prop up exports and counter weak domestic 

demand.30

On December 11, 2015, the PBC indirectly hinted at another change in policy, posting on its 

website an article indicating that the CFETS would begin publishing a set of trade-weighted 

exchange rate indexes. The piece lays out the logic, noting that “For quite long, market 

participants have used bilateral exchange rate of RMB against USD to assess RMB exchange 

rate movements. However, as fluctuations of exchange rate serve to adjust trade and investment 

activities with multiple trading partners, the bilateral RMB-USD exchange rate is not considered 

a good indicator of the international parity of tradable goods. Therefore, it is more desirable to 

refer to both the bilateral RMB-USD exchange rate and exchange rate based on a basket of 

currencies.” The piece makes it clear that the objective of publishing the index is to “bring about 

a shift in how the public and the market observe RMB exchange rate movements.”31

The CFETS has indicated that it will publish three exchange rate indexes—one based on the 

thirteen currency pairs with the RMB trading on the CFETS; one based on the much larger set of 

countries used by the Bank for International Settlements (BIS) to calculate its indexes; and a 

separate index based on the four major reserve currencies (the dollar, the euro, the yen, and the 

British pound sterling). The RMB-dollar exchange rate would receive a weight of at most 42 

 30 See “China moves to devalue yuan” Wall Street Journal, August 11, 2015.

31 PBC Notice by Guest Commentator of CFETS “The Launch of RMB Index Helps to Guide Public 

View of RMB Exchange Rate,” December 11, 2015

http://www.pbc.gov.cn/english/130721/2988680/index.html.
31

percent in these indexes. In the BIS index, the dollar would have a weight of only 18 percent, 

consistent with the amount of China’s trade accounted for by the United States.

32

This approach appears to reflect a change in the PBC’s strategy regarding both practice and 

communications. First, by finally putting into practice a policy that had in principle been in 

operation since 2005, this move would make it easier for the PBC to delink the RMB from the 

dollar. Second, the PBC may be preparing the market for further RMB depreciation relative to 

the dollar in the short run—if the dollar were to strengthen further—and focusing attention on a 

more suitable benchmark for future movements in the currency. However, the PBC has not 

revealed what currencies will be in the basket that the RMB’s value is managed against and what 

the weights on those currencies will be. 

3.2. Onshore and Offshore Exchange Rates

By limiting the flow of money across China’s borders, the capital account restrictions described 

in Chapter 2 help control the value of the RMB, which now trades on both onshore (CNY) and 

offshore (CNH) markets. Onshore trade takes place through the CFETS, which is in effect 

managed by the PBC. The offshore trades take place mostly on the Hong Kong Interbank 

Market. Mainland government regulations mandate these separate markets for trading RMB. The 

onshore market is subject to the mainland’s capital account restrictions and the RMB’s value on 

that market is therefore controlled by the PBC to a greater extent. In contrast to the CNY market, 

the CNH market is not normally subject to intervention or direct official control by the PBC.

Before 2010, RMB-related activities in the offshore market were quite limited, often contributing 

to a marked deviation of the CNH exchange rate from that of the CNY—the RMB was typically 

more valuable offshore. The two exchange rates became more closely linked after a series of 

developments in the last quarter of 2010 boosted RMB-denominated financial transactions. 

These developments include the approval granted to financial institutions and banks in Hong 

Kong to open RMB accounts and for Hong Kong banks to access the onshore interbank market,

activation of a swap line between the PBC and the Hong Kong Monetary Authority, and a flurry 

of RMB-denominated bond issuance activities. These measures have lowered transaction costs 

for eligible financial market participants to access both markets. As a result, the two rates have 

moved in lockstep for much of the period since the end of 2010, reflecting the rising integration 

of China’s onshore and offshore financial markets.

 32 PBC Notice by Guest Commentator of CFETS “The Launch of RMB Index Helps to Guide Public 

View of RMB Exchange Rate,” December 11, 2015

http://www.pbc.gov.cn/english/130721/2988680/index.html.
32

Figure 3-3 shows that, from January through July 2015, the two rates generally moved together, 

with only narrow spreads between them. However, that trend changed dramatically in August. 

The shift in the exchange rate regime that was combined with a currency devaluation on August 

11, 2015 set off a sharp divergence between the two rates. For much of the remainder of the 

month, the RMB was worth less on the offshore than on the onshore markets, reflecting 

downward pressures on the RMB as markets appear to have interpreted the government’s move 

as possibly being the first in a series of devaluations intended to support the weak economy by 

boosting exports. By intervening in the CNY market, the government was able to limit the 

downward pressures on the RMB–dollar exchange rate but at the cost of opening up a spread 

between the onshore and offshore rates. By mid-September 2015, this gap between the CNY and 

CNH exchange rates had been closed. Press reports suggest that the PBC and Chinese stateowned commercial banks intervened directly by buying RMB in the CNH market to facilitate 

this outcome.33 It remains to be seen if this forced convergence of the two rates is sustainable, or 

if the PBC will allow the onshore rate to float more freely, leading to a natural, market-led 

convergence of the two rates.

Figure 3-3. Onshore (CNY) and Offshore (CNH) Spot RMB-Dollar Exchange Rates

Source: Bloomberg

Notes: This chart shows daily data (end of the day) on the onshore and offshore spot exchange rate

markets. The spread is defined as the USD/CNY minus USD/CNH.

 33 See, for instance, “China central bank seen ready to intervene again if offshore pushes yuan too far,” 

Reuters, September 11, 2015, and “China’s offshore currency rate jumps in late trade,” Financial Times, 

September 10, 2015. 

-0.15 

-0.11 

-0.08 

-0.04 

0.00 

0.04 

6.0 

6.2 

6.3 

6.5 

6.6 

Dec-14 Feb-15 Apr-15 May-15 Jul-15 Aug-15 Oct-15 

Spread (right scale) 

USD/CNY 

USD/CNH 
33

3.3. External Balances and Reserves

China’s external imbalances have to a large extent dissipated since the global financial crisis. 

China’s current account and trade surpluses have shrunk relative to their peaks in 2007, when 

they hit 10.1 percent of GDP and 7.6 percent of GDP, respectively. On a rolling four-quarter 

basis, the two ratios stood at 2.8 percent and 3.4 percent, respectively, in the third quarter of 

2015 (Figure 3-4). The merchandise trade balance (goods only) rose to 5.5 percent in 2015, 

reflecting falling imports and a slight recovery in exports towards the end of the year. Imports 

have fallen mainly because of a decline in import prices, especially commodity imports.34

Figure 3-4. China: Current Account and Trade Balance

(in percent of GDP)

Sources: State Administration of Foreign Exchange and National Bureau of Statistics

Notes: The current account balance (dark solid line),the goods and services trade balance (dashed line), 

and the merchandise trade balance (goods only; light solid line) are shown as ratios to nominal GDP. The 

figure shows four-quarter trailing moving averages for all three variables. 

China’s foreign exchange reserves, which peaked at nearly $4 trillion in the second and third 

quarters of 2014, fell to about $3.53 trillion by October 2015 (Figure 3-5). Reserves had been 

rising quite steadily for a number of years until the second half of 2014, when they fell by $150 

billion. This fall was partly accounted for by valuation effects as the U.S. dollar value of China’s 

holdings of euro- and yen-denominated assets declined due to the depreciation of those 

currencies relative to the dollar. The remainder signals intervention by the PBC to keep the 

RMB’s value relative to the dollar stable in the face of large shifts in its balance of payments. 

 34 See “China trade surplus swells as exports rise in boost for yuan,” Bloomberg News, January 12, 2016.

0	

2	

4	

6	

8	

10	

12	

2005	 2006	 2007	 2008	 2009	 2010	 2011	 2012	 2013	 2014	 2015	

Current	Account	

Trade	Balance	(Goods	+	Services)	

Trade	Balance	(Goods)	
34

This fall in China’s reserves appears to have picked up pace during 2015. There was a 

particularly large decline of about $94 billion in August and another $43 billion in September, 

before the position stabilized in October. Reserve losses then picked up again, amounting to a 

total of $195 billion during November and December, as depreciation pressures on the RMB 

intensified. Overall, reserves fell by $512 billion during 2015.35

These shifts in patterns of reserve accumulation are attributable to two factors—the lower level 

of China’s trade surplus in recent years and the deficit on the capital account, implying that more 

capital (other than accumulation of reserves) flowed out of the country relative to the amount 

that came in. This shift represents an important change in the nature of China’s overall capital 

exports (which is roughly equivalent to the current account surplus). Balance of payments data 

show that in 2014, China’s current account surplus was $214 billion while the increase in 

international reserves, which effectively amounts to official capital outflows, was $22 billion. 

This implies that private net capital outflows amounted to about $192 billion. 

The capital account deficits have sparked concerns about capital flight, with the connotation 

being that some domestic residents and corporations, concerned about China’s domestic 

macroeconomic and financial situation, are sending capital out of the country. A more benign 

interpretation is that rising capital outflows are a natural consequence of steps that China is 

taking to open up its capital account and remove restrictions on outflows. As the economy 

matures and financial markets develop, domestic retail and institutional investors will look to 

foreign investments as a way of diversifying their portfolios. Moreover, Chinese corporations 

and financial institutions are investing abroad to diversify their operations and as a conduit for 

acquiring technical and managerial expertise. The discussion in Chapter 2 shows that this is a 

trend shift that has been encouraged by the government’s capital account liberalization measures. 

In recent months, however, fears about capital flight have been heightened by concerns about the 

growth slowdown and the stock market decline. This issue is discussed in greater detail in 

Chapter 8. 

 35 Figures based on SAFE data obtained via CEIC. Also see “PBOC in a Quandary Over Capital 

Controls,” Financial Times, January 25, 2016.
35

Figure 3-5. China: Foreign Exchange Reserves

Source: PBC

3.4. Foreign Exchange Trading

The PBC set up an interbank currency market, the CFETS, in April 1994 with its headquarters in 

Shanghai.36 The CFETS remains under the direct control of the PBC. The CFETS initially had a 

trading system that focused mainly on the RMB–dollar exchange rate but has since expanded, 

with a broad range of foreign currency trading introduced in 2005. The functions of the CFETS 

include: providing trading, information, benchmark, and training facilities to the interbank 

lending, bond and FX markets; monitoring market transactions; providing services for the 

operation and transmission of the PBC’s monetary policy actions; and engaging in other 

businesses authorized by the PBC.

The internationalization of the RMB would be assisted by smooth trading of currencies in a wellorganized market that features multiple currencies, sufficient liquidity, and large numbers of 

participants as well as market makers. To this end, the Chinese government has taken a number 

of steps in recent years to improve the functioning of the CFETS. 

 36 The headquarters is in Zhangjiang, Shanghai, with a local back-up center on the Bund and a remote 

back-up center in Beijing. Sub-centers of CFETS have also been set up in 18 provincial capitals and 

major cities of economic regions throughout the country, including Chengdu, Chongqing, Dalian, Fuzhou, 

Guangzhou, Haikou, Jinan, Nanjing, Ningbo, Qingdao, Shantou, Shenyang, Shenzhen, Tianjin, Wuhan, 

Xiamen, Xi'an, and Zhuhai.

-3	

-2	

-1	

0	

1	

2	

3	

4	

-100	

-50	

0	

50	

100	

150	

2005	 2006	 2007	 2008	 2009	 2010	 2011	 2012	 2013	 2014	 2015	

Total	(Trillions$)	

Monthly	Accumulation	(Billions$)	

Monthly	Accumulation	

Total	
36

The instruments now traded in the FX/RMB spot market cover 12 currency pairs with the CNY,

including the U.S. dollar, euro, Japanese yen, Hong Kong dollar, British pound sterling,

Australian dollar, New Zealand dollar, Singapore dollar, Canadian dollar, Malaysian ringgit,

Russian ruble, and Thai baht. A few currency pairs without the CNY can also be traded, such as

the U.S. dollar–euro, U.S. dollar–Japanese yen, and euro–Japanese yen.

Members exchange RMB and FX at contracted currencies, amounts, and exchange rates, and

settle or deliver within two business days. There are two types of trades that can be executed on

the CFETS: anonymous and bilateral. For anonymous trading, institutions post the buy and sell

rates based on the middle rates set by the PBC every day, and the CFETS centralized platform

then matches the bids and provides clearing services as the central counterparty. For bilateral

trading, FX dealers, or the market makers, facilitate transactions by buying and selling foreign

exchange with other parties separately, clearing and settling with each other according to the

agreement. There is no difference between domestic and foreign institutions in terms of

operating rules and procedures.

The CFETS initially had only a small set of state-owned banks as market participants. The 

system has been opened up considerably over the years. As of November 2015, there are 499 

financial and non-financial institutions approved as market members licensed to trade on the spot 

foreign exchange markets. The list comprises banking institutions, including not only the holding 

companies of domestic and foreign banking institutions but also the local and foreign branches of 

these banking corporations in selected provinces and cities. There are nearly 100 foreign-funded 

financial institutions as approved members, while the rest are domestic institutions. A breakdown 

of the listed institutions by category is shown in Table 3-1.

Table 3-1. Categories of Members Licensed to Operate on the CFETS

Categories Examples

Big commercial banks Industrial and Commercial Bank of China 

(ICBC), Bank of China (BOC), Agricultural 

Bank of China (ABC), China Construction 

Bank (CCB)

Local branches of domestic commercial banks ICBC Guangxi Branch, ICBC Yunnan Branch

Foreign branches of domestic commercial 

banks

BOC Paris Branch, BOC Limited Manila 

Branch, Bank of Communications Seoul 

Branch

Domestic private banks China Merchants Bank, China Everbright 

Bank, HuaXia Bank, China Guangfa Bank, 

Ping An Bank
37

Policy banks The Export–Import Bank of China, China 

Development Bank, Agricultural Development 

Bank

Rural commercial banks Tianjin Rural Commercial Bank, Shanghai 

Rural Commercial Bank

City banks Bank Of Beijing, Chongqing Commercial 

Bank, 

Subsidiary financial companies of big SOEs China Huaneng Finance Corporation, COFCO 

Finance Corporation, CNOOC Finance 

Corporation, China Power Finance 

Corporation, Sinopec Finance

Subsidiary financial companies of big private 

companies

Media Group Finance Corporation, Haier 

Finance

Foreign banks Morgan Stanley, BNP Paribas (China), East 

West Bank (China), Barclays Bank PLC. 

Shanghai

Source: CFETS 

In 2005, a market-making system was introduced on the CFETS. Under this system, a group of 

participants are designated market makers, assuming the role of facilitating transactions on the 

exchange. Such institutions play an important part in the smooth functioning of markets as they 

provide liquidity by being prepared to buy and sell the currencies traded on that market (i.e., 

during trading hours they always display buy and sell quotations for a minimum number of 

shares). Financial institutions, either domestic or foreign, applying to be market makers have to 

hold market membership for two years or longer and pass through another two-year trial period. 

Basic requirements include a capital adequacy ratio of the entire bank of at least 8 percent in the 

preceding year (a high ranking in terms of the size of transactions) and clean regulatory 

compliance records.

There are currently 30 banking institutions serving as market makers in the spot markets, 

including the big major state-owned banks, policy banks such as China Development Bank, 

private-owned banks such as Everbright Bank and Minsheng Bank, local-level city banks such as 

Bank of Shanghai and Nanjing City Bank, and foreign banks such as Bank of America (China), 

CitiBank (China), and HSBC (China). There are four other foreign banks, such as J.P. Morgan 

(Shanghai), that are also operating as market makers on a trial basis. The full list is tabulated 

below.
38

Table 3-2. Market Makers in the Spot Foreign Exchange Markets

Domestic Banks as RMB/FX Spot Market

Makers (19)

Foreign Banks as RMB/FX Spot Market

Makers (11)

ICBC, BOC, ABC, CCB, Bank of

Communications, China CITIC Bank, China

Merchants Bank, China Everbright Bank,

HuaXia Bank, China Guangfa Bank, Ping An

Bank, Industrial Bank, China Minsheng

Banking, China Development Bank, Postal

Savings Bank of China, Bank Of Shanghai,

Nanjing City Commercial Bank, Bank of

Ningbo, Shanghai Pudong Development Bank.

BNP Paribas (China), DBS Bank (China),

Bank of America-Shanghai, HSBC Bank

(China), Bank of Montreal (China), CitiBank

(China), Standard Chartered Bank (China),

Sumitomo Mitsui Banking Corporation China,

Deutsche Bank (China), Mizuho Bank (China),

Bank of Tokyo-Mitsubishi UFJ Ltd. Shanghai

Branch.

Source: CFETS
39

4. China’s Domestic Financial Markets

Financial market development in the home country is one of the key determinants of a currency’s 

international status.37 Historically, each reserve currency has risen on the international stage 

under unique circumstances, spurred by a range of motivations, but one constant is that this rise 

has always required financial markets that can cope with the varied and voluminous demands of 

private and official foreign investors. There are three relevant aspects of financial market 

development:

• Breadth: The availability of a broad range of financial instruments, including markets for 

hedging risk.

• Depth: A large volume of financial instruments in specific markets.

• Liquidity: A high level of turnover (trading volume).

Without a sufficiently large and liquid debt market, the RMB cannot be used widely in 

international transactions. To make the currency attractive to foreign central banks and large 

institutional investors, they will need access to RMB-denominated government and corporate 

debt as “safe” assets for their portfolios. At the same time, both importers and exporters may be 

concerned about greater exchange rate volatility resulting from an open capital account if they do 

not have access to derivatives markets to hedge foreign exchange risk. Thus, depth, breadth, and 

liquidity are all relevant considerations in assessing the readiness of a country’s financial sector 

to cope with an open capital account and elevate its currency to reserve currency status. 

4.1. The Banking System

China’s financial system remains bank-dominated, with the state directly controlling most of the 

banking system. Domestic credit allocation is controlled largely by state-owned banks and is 

disproportionately directed toward enterprises, especially state-owned enterprises, rather than 

households. Credit allocation through the banking sector is supported by massive deposits in the 

banking system, amounting to 179 percent of GDP in 2014 (Figure 4-1). Corporate deposits 

amount to 89 percent of GDP and household deposits are about 80 percent of GDP. The ratio of 

M2 to GDP was 193 percent in 2014.38

Growth in bank loans and money supply, which hit peaks of 34 percent and 30 percent, 

respectively, in 2009 as part of the stimulus effort in the aftermath of the global financial crisis, 

have mostly been in the range of 10–15 percent since 2012 (Figure 4-2). But this is on top of a 

much bigger base as the credit surge in 2009-10 meant a substantial increase in the stock of 

outstanding bank loans.

 37 On the importance of home country financial market development for a currency to become a reserve 

currency, see Tavlas (1991), Chinn and Frankel (2007), Forbes (2009), and Obstfeld (2011). 

38 M2 is a monetary aggregate that includes cash, demand deposits, savings deposits, retail money market 

mutual fund shares, and small-denomination time deposits (less than $100,000). 
40

Figure 4-1. China: Bank Deposits and Money Supply

(in percent of GDP)

Sources: PBC, National Bureau of Statistics via CEIC

Figure 4-2. China: Bank Loans and Money Supply

(year over year growth; in percent)

Source: PBC

The size and structure of the banking sector in China seem unsuitable for promoting the 

international use of the RMB on a large scale. Policies that favor the banking sector relative to 

0	

50	

100	

150	

200	

250	

2000	 2001	 2002	 2003	 2004	 2005	 2006	 2007	 2008	 2009	 2010	 2011	 2012	 2013	 2014	

Enterprise	

Households	

Other	

M2	

0.0	

5.0	

10.0	

15.0	

20.0	

25.0	

30.0	

35.0	

40.0	

Jan-05	 Jan-06	 Jan-07	 Jan-08	 Jan-09	 Jan-10	 Jan-11	 Jan-12	 Jan-13	 Jan-14	 Jan-15	

Money	Supply	(M2)	

Total	Bank	Loans	
41

the rest of the financial system—including the interest rate structure that until recently inhibited 

competition by setting a floor for lending rates and a ceiling for deposit rates—have been 

detrimental to broader financial market development.

Recognizing this, the Chinese government has instituted a number of reforms in recent years. 

Bank deposit and lending rates have now been fully liberalized. Commercial banks can now set 

these rates freely, although the PBC still sets reference rates to guide banks. An explicit bank 

deposit insurance program has also been in operation since May 2015. This program is intended 

to expose banks to some degree of market discipline by replacing the implicit full insurance of 

all deposits by the government. Deposits are covered up to a ceiling of RMB 500,000, which is 

roughly 13 times China’s per capita income. The deposit insurance system covers 99.6 percent of 

deposit accounts but only about half of the deposit base. This is because most of the roughly 5 

billion bank accounts in China (many households have multiple accounts) have relatively small 

deposits, while large deposits of corporations, institutions, and wealthy individuals account for 

the bulk of the deposit base. Participation in the deposit insurance system is mandatory for all 

deposit-taking institutions, and the premiums are risk-based, with factors such as capital 

adequacy ratios and corporate governance structures affecting premiums. The system also allows 

for early intervention by the banking regulator and has an improved resolution mechanism for 

failing banks. Since the system is relatively new, there have been no test cases as yet.

These reforms are important steps in the right direction. Future reforms and development of the 

banking system will have significant implications for the development of China’s more nascent 

financial markets, including the corporate bond market (Hale, 2007), and also for economic 

development more broadly. The credit distortions in the banking system have hampered the 

development of a more competitive domestic private enterprise sector. It will be difficult to 

achieve a liquid debt market without more active participation from private firms as well as 

households. 

4.2. Shadow Banking39

Shadow banking refers to financial activities outside the normal banking system. The Financial 

Stability Board describes it as involving credit intermediation through entities and activities 

outside the regular banking system. This definition implies that banks can also engage in shadow 

banking activities that are outside their traditional roles of deposit-taking and loan creation.

China’s shadow banking sector has expanded rapidly as a way around many of the regulations 

imposed on the formal banking system including (until recently) controlled interest rates, a high 

level of reserve requirements on bank deposits, and rising demand for financial intermediation 

services that are not satisfied by traditional institutions or conventional banking products (both 

for savings and credit).

Definitions of the shadow banking system vary, but the major categories of credit that fall under 

its rubric include:

 39 The discussion and data in this section draw on IMF (2015), Elliott, Kroeber, and Qiao (2015), and 

Jiang (2015). 
42

• Entrusted loans: Loans that involve nonfinancial corporates as borrowers and lenders, 

with banks acting as intermediaries but bearing none of the credit risks.

• Trust loans: Financial transactions undertaken by trust companies that are regulated 

separately from banks and have some characteristics of banks and fund managers.

• Bank acceptances: Instruments issued by banks that commit to pay a fixed amount in a 

given period and that are backed by deposits of the party seeking these certificates. These 

certificates can in turn be used to back commercial transactions. 

There is a range of other instruments that are also often included in definitions of the shadow 

banking system, including wealth management products (WMPs) that offer higher returns than 

traditional bank deposits and that can even be offered by banks themselves. Other credit 

instruments include guarantees, peer-to-peer lending, financial leasing, and also credit provided 

by pawnshops and other unofficial lenders.

By the IMF’s conservative definition, which comprises the three main items noted above 

(entrusted loans, trust loans, and bank acceptances), China’s level of social financing is currently 

about 34 percent of GDP (Figure 4-3). Broader definitions of shadow banking that include other 

items, even on occasion including corporate bond markets, can lead to substantially higher 

estimates of the size of China’s shadow banking system. Even by these broader estimates, the 

shadow banking system is not large relative to that in many advanced economies, although its 

growth rate in China in recent years is certainly among the highest in the major economies. A 

recent paper from Columbia University estimates that based on figures from Moody’s shadow 

banking assets amount to 65 percent of GDP in China, compared with 150 percent in the United 

States and a world average, weighted by country size, of about 120 percent.

40

Table 4-1 shows an alternative breakdown of total social financing (TSF), a measure that 

includes bank loans, shadow banking, corporate bond financing, and other forms of credit. This 

concept provides a useful measure of broader developments in credit creation in the Chinese 

economy since the relative importance of bank loans in overall credit has been declining. The 

stock of TSF amounted to 193 percent at the end of 2014. 

 40 See Jiang (2015).
43

Figure 4-3. Social Financing

(in percent of GDP)

Source: IMF Staff Report on China, 2015

Note: In percent of four quarter rolling sum of quarterly GDP.

Table 4-1. Total Social Financing Components

(in percent of GDP)

Source: IMF Staff Report on China, 2015
44

Figure 4-4 shows that growth rates of private credit and total social financing have followed a 

similar trajectory in recent years. Total social financing growth has fallen sharply from a peak of 

about 34 percent in 2009 to 12 percent in mid-2015.

Figure 4-4. Total Social Financing and Private Credit

(in percent, year-on-year)

Source: IMF Staff Report on China, 2015

Concerns about the financial stability risks posed by the growth of shadow banking have 

prompted the Chinese authorities to impose stricter regulation of shadow banking activities, both 

by banks and nonbank financial entities. Off-balance sheet activities by the commercial banks 

could affect their risk profiles. While trust companies and other nonbank financial entities are not

backed by the government, their liabilities pose broader risks as they could become liabilities of 

the state. Concerns that the failure of any such institution could undermine confidence in the 

overall financial system implicitly result in government backing of these institutions, which in 

turn allows them to expand their balance sheets with limited regulatory oversight. 

In December 2013, the State Council issued an internal document (Circular No. 107) laying out 

conceptual issues regarding the scope of shadow banking, associated regulations, and their policy 

implications. The document mainly set out broad principles, and it took time for rules to be 

promulgated and for concrete implementation measures to be put in place. With rising concerns

about the financial stability implications of the shadow banking sector, various regulatory 

concerns have stepped up their oversight of this sector. Much of this attention has been focused 

on WMPs. A selected set of key regulatory measures instituted following the issuance of the 

State Council guidelines is as follows:
45

• Commercial banks are required to establish a specific department for WMPs and to set up 

a specific accounting system for these products. Funds raised by WMPs are not to be 

used to invest in own lending assets.41

• Trust companies are subject to the following regulations, which means that companies 

are: (i) forbidden from conducting “fund pools” business, a common practice that enabled

these companies to finance cash payouts by selling new WMPs; (ii) required to reduce 

lending when their capital levels fall due to losses; and (iii) required to establish a 

mechanism for managing crises, including delaying executives’ incentive compensation, 

restricting dividend payouts, and disposing of some businesses.

42

• CBRC imposed a minimum asset requirement of RMB 3 billion (about $475 million) and 

restricted the scope of trust funds that can be invested in by insurance companies. 

Imposed system restrictions on interbank operations, such as repos and interbank 

borrowing/lending, and also set capital, accounting, and maturity requirements on 

interbank operations.

43

• Commercial banks are required to report WMP operations to CBRC, starting at the end of 

July 2014.44

• CBRC assigns grades to trust companies and implements discretionary regulation rules 

depending on their grades.45

• CIRC highlighted the risks of insurance investment in trust funds and required insurance 

companies to comply with the regulation rules.

46

• The trust industry insurance fund company is jointly established by China Trustee 

Association and 13 trust firms, with registered capital of nearly RMB 10 billion (about 

$1.5 billion). Trust companies are required to subscribe to the insurance fund in an 

amount equal to one percent of assets under management. The fund is to be used in 

emergencies for providing short-term liquidity and assisting in the restructuring of a 

distressed trust company.

47

• Commercial banks are barred from bearing credit risks for entrusted loans. Entrusted loan 

investments in securities, futures, stocks, and financial derivatives are prohibited.

48

As a result of these measures, the flow of total social financing has fallen sharply, led by a 

decline in shadow banking (Figure 4-5). In some recent months, the flow of credit associated 

with shadow banking has been small or even negative. This trend can also be seen in Figure 4-6, 

which shows that the fall in total social financing on a year-over-year basis is closely tracked by 

the fall in the contribution of shadow banking to overall growth in financing. 

 41 CBRC, February 2014.

42 CBRC, April 2014.

43 CIRC, May 2014.

44 CBRC, June 2014.

45 CBRC, August 2014.

46 CIRC, October 2014.

47 CBRC, December 2014.

48 CBRC, January 2015.
46

Figure 4-5. Social Financing Flow

(in trillions of RMB)

Source: IMF Staff Report on China, 2015

Figure 4-6. Social Financing Stock

(in percent, contribution to growth)

Source: IMF Staff Report on China, 2015
47

Although it is seen as a dangerous part of the financial system, the shadow banking system does 

have the potential to play a useful role in improving the allocation of resources in the economy. 

In particular, many private corporations, including small and medium-sized enterprises, rely on 

this system for the credit that they are unable to procure from traditional banks. WMPs, despite 

their inherent risks, have also been seen as a means of indirect liberalization of deposit rates. A 

better-regulated shadow banking system could complement the activities of the traditional 

banking sector and also catalyze changes and efficiency improvements in that sector. 

But shadow banking is nontransparent and has no formal safety backstops, such as the support of 

a deposit insurance mechanism. The lack of tight regulation of many shadow banking activities, 

in tandem with the assumption on the part of many market participants that there is an implicit 

government guarantee backing these activities, could be a dangerous combination. The 

government has endeavored to disabuse market participants of this notion, including by its 

willingness to consider allowing trust companies and other institutions to fail. In its present form 

and at current levels, it is unlikely that the shadow banking system by itself poses significant 

threats to overall financial stability. Nevertheless, the government has been concerned that risks 

in this sector could translate into vulnerabilities in the formal banking system (given the 

connections between the two sectors through products such as WMPs) and therefore continues to

monitor developments in this sector with considerable apprehension. 

4.3. Equity Markets 

One dimension along which China has made progress is the development of its equity markets. 

There are two main exchanges in China—Shanghai and Shenzhen—and two classes of shares 

traded on both markets. A shares are denominated in RMB and, until 2002, foreign investors 

could not purchase these shares. B shares have a face value in RMB but are listed for trading 

primarily to foreign investors in foreign currency (in U.S. dollars on the Shanghai exchange and 

in Hong Kong dollars on the Shenzhen exchange). Local Chinese companies can issue both types 

of shares, although B shares tend to trade at a discount relative to the same company’s A 

shares.49 This is due, in part, to the A share market’s much larger trading volumes. In 2001, the B 

share market was opened to domestic investors with foreign currency accounts. Since 2002, 

when the QFII scheme was introduced, foreign investors have had access to the A share market. 

Until 2005, about two-thirds of the stock market in China was composed of non-tradable shares, 

which were owned directly by the government or state-owned financial institutions. In that year, 

reforms were introduced to allow non-tradable shares in Chinese companies to float freely. These 

reforms had a dramatic effect. Market capitalization started to rise after these reforms, surging 

sharply in 2007 before the financial crisis of 2008-2009 led to a sharp decline (Figure 4-7). 

Trading volumes on both exchanges (turnover) also began to rise in the aftermath of the reforms. 

Capitalization and turnover in Chinese equity markets now exceed those of most other 

economies—with the notable exception of the United States, which remains dominant in terms of 

its share of global equity market capitalization and turnover. The number of listed firms on the 

 49 With government approval, Chinese companies can also list on the Hong Kong exchange, where their 

share prices are quoted in Hong Kong dollars. These instruments are called H shares. 
48

Shanghai and Shenzhen stock exchanges has increased steadily from 1,086 in 2000 to 2,799 as of 

November 2015 (Figure 4-8). 

Figure 4-7. Stock Market Capitalization

(in trillions of U.S. dollars)

Sources: Shanghai Stock Exchange, Shenzhen Stock Exchange, and SAFE via CEIC

0 

1 

2 

3 

4 

5 

6 

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 

Shanghai Stock Exchange 

Shenzhen Stock Exchange 
49

Figure 4-8. The Number of Listed Companies in China’s Stock Markets

Source: CEIC

Notes: The data shown above, which comprise listed companies on both the Shanghai and Shenzhen 

exchanges, are for the end of each year. Data for 2015 are for November. 

Equity markets do, in principle, provide RMB-denominated instruments that can be held by both 

domestic and foreign investors and, as noted in Chapter 2, there is an increasing number of 

channels in which foreign investors can participate, even in China’s A share market. The level of 

foreign investor participation remains limited, however, relative to overall stock market 

participation because of restrictions on foreign equity investments.

Moreover, Chinese stock markets are highly volatile. Starting in early 2014, both stock market 

indexes began to rise sharply and more than doubled in just over a year. Despite some regulatory 

measures taken in early 2015 to limit margin lending (loans that are used to invest in stocks), the 

stock market run continued until June 2015 (Figure 4-9). With regulatory tightening and rising 

concerns about an economic slowdown, stock prices then began to plummet from their peak. 

0 

700 

1400 

2100 

2800 

3500 

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 
50

Figure 4-9. Shanghai and Shenzhen Stock Market Indices

Sources: Shanghai Stock Exchange and Shenzhen Stock Exchange via CEIC

This prompted a series of measures by the government to limit the stock market turmoil. Some of 

these measures were heavily interventionist and, although described as emergency measures, 

they have hurt the credibility of the government and created doubts about its attitude toward 

market-oriented reforms. The measures included propping up stock prices and also limiting

activity that could push down prices.50

The key measures that were taken to mitigate downward pressures on stock prices include:

• Limitations on short selling, with the CSRC threatening to arrest those engaged in 

“malicious short selling”

• A ban on initial public offerings for four months starting in July

• Suspension of trading in the shares of over a thousand firms

• A six-month ban on stock sales by stockholders with a 5 percent or higher equity stake in 

a given company

Measures to prop up prices through direct intervention include:

 50 See, for instance, “China Security Ministry to probe ‘malicious’ short selling,” Bloomberg, July 8,

2015; “China rolls out emergency measures to prevent stock market crash,” Reuters, July 5, 2015; “China 

central bank pledges liquidity support to stock market,” Bloomberg, July 7, 2015; “China stock 

exchanges step up crackdown on short-selling,” Reuters, August 4, 2014; “China punishes nearly 200 

over ‘rumors’ about stocks, blasts and parade,” New York Times, August 31, 2015; “China reporter 

confesses to stoking market ‘panic and disorder,’” Financial Times, August 31, 2015. Official documents 

include: “Notice on Modifying Article 15 of ‘SSE Detailed Rules for Implementation of Margin Trading 

and Securities Lending (Revised in 2015)’ ”(Shanghai Stock Exchange, August 3, 2015); “SZSE Amends 

Rules for Margin Trading and Securities Lending” (Shenzhen Stock Exchange, August 4, 2015).

0 

1000 

2000 

3000 

4000 

5000 

6000 

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 

Shanghai Stock Exchange 

Shenzhen Stock Exchange 
51

• New rules allowing pension funds to invest up to 30 percent of their net assets in equities 

(previously, pension funds could not invest in equities)

• Relaxation of rules on margin financing

• Giving banks permission to make corporate loans using equity as collateral

• A PBC pledge to lend RMB 250 billion ($40 billion) to major brokerage firms through 

the China Securities Finance Corporation to help them cope with liquidity shortages

• State-owned funds and institutions encouraged to buy stocks

Other propaganda measures included news articles in official media blaming “foreign forces” for 

the stock market turbulence. In addition, nearly 200 people were arrested for allegedly spreading 

false information that caused the market crash. Those arrested included financial practitioners, 

regulatory officials, and also financial journalists.51

The government’s other actions to stabilize the market have not inspired confidence either. On 

January 4, 2016, the CSRC introduced a circuit breaker mechanism in the Chinese stock 

market.52 This led to a negative reaction in markets, with the main indexes plunging by about 14 

percent over the next three days. The circuit breakers were activated multiple times during that 

period, worsening the sell-off as many market participants tried to sell their holdings before the 

circuit breakers were activated. The circuit breaker was deactivated three days after its 

introduction.53

Chinese stock markets have been prone to concerns about weak corporate governance, limited 

transparency, weak auditing standards, and shoddy accounting practices. In the absence of broad 

institutional and regulatory reforms that are necessary to support effective price discovery and 

the overall efficient functioning of stock markets, these markets could remain unstable.54 The 

recent volatility in the stock market and the manner in which the government has addressed it has 

heightened many of these concerns. As a consequence, even with more liberalization of portfolio 

inflows, international investors may shy away from investing heavily in Chinese equities. 

Therefore, the country’s deep equity markets may be of limited help in promoting the 

international role of the RMB.

4.4. Debt Markets

China’s fixed income markets, especially for corporate debt, have developed considerably in the 

last few years (Table 4-2). The stock of government bonds stands at about $3.5 trillion, nearly a 

fivefold increase over the last decade and now equivalent to about one-third of GDP. 

Nonfinancial corporate debt was practically nonexistent a decade ago, but the outstanding stock 

has now risen to about $1.5 trillion. Turnover, a measure of trading volume, remains quite low in 

both markets, however. China has maintained a number of restrictions on foreign investors’ 

participation in its bond markets, which could adversely affect the RMB’s efforts to become a 

 51 “China punishes nearly 200 over ‘rumors’ about stocks, blasts and parade,” New York Times, August 

31, 2015.

52 “China’s latest step to curb stocks’ wild ride: Circuit breakers,” CNBC.com, January 4, 2016. 

53 “China Suspends Stock Circuit Breaker Days After Introduction,” Bloomberg News, January 7, 2016.

54 See Eswar Prasad, “China’s Fitful Economic Reforms,” The International New York Times, December 

2, 2015. http://www.nytimes.com/2015/12/02/opinion/chinas-fitful-economic-reforms.html.
52

reserve currency. In recent years, China has started creating channels, including through the QFII 

scheme, for foreign institutional investors to purchase both government and corporate debt 

securities in China. 

Table 4-2. Government and Corporate Bonds in China: Stocks and Turnover

Year

Government Bonds Corporate Bonds

Level (USD 

billions)

Turnover 

(USD 

billions)

Turnover 

Ratio

Level (USD 

billions)

Turnover 

(USD 

billions)

Turnover 

Ratio

2002 328 ... ... 7 ... ...

2003 424 ... ... 12 ... ...

2004 570 ... ... 22 ... ...

2005 788 ... ... 54 ... ...

2006 1,038 ... ... 98 ... ...

2007 1,426 ... ... 140 ... ...

2008 1,898 ... ... 230 ... ...

2009 2,062 ... ... 427 ... ...

2010 2,349 ... ... 618 ... ...

2011 2,459 ... ... 797 ... ...

2012 2,725 ... ... 1,176 ... ...

2013 2,952 496 0.17 1,416 263 0.18

2014 3,341 1,053 0.31 1,543 306 0.20

2015 3,515 1,885 0.54 1,570 425 0.27

Source: AsianBondsOnline, Asian Development Bank, and author's calculations

Notes: Turnover is defined as the value of bonds traded on the secondary market. Turnover ratio is defined 

as total turnover divided by the average value of bonds outstanding between the end of the third and fourth 

quarters of each year. Repurchase transactions are excluded. Corporate bonds include those issued by 

nonfinancial and financial corporations. The BIS revised the compilation methodology for debt securities 

statistics in 2012. While the revised stock data on outstanding bonds are consistent over time, recent

turnover data are not consistent with data prior to 2013, so data for prior periods are not shown. An ellipsis 

indicates missing data (based on the revised statistics). Data for 2015 are for June of that year. 

China’s overall domestic debt market was valued at $5 trillion in 2014, significantly lower than 

the top three reserve currency areas—the United States, Japan, and the euro area (Table 4-3). The 

U.S. domestic debt securities market has a capital value four times that of China. Interestingly, 

the quantity of China’s outstanding domestic securities is greater than that of the United 

Kingdom and Switzerland, two reserve currency economies.55 This suggests that the size of the 

domestic debt market per se does not necessarily prevent the Chinese currency from going 

global. However, the degree of turnover in China’s government and corporate bond markets is 

low, indicating that the liquidity of debt markets in China does not measure up to that of other 

reserve currency economies’ debt markets. This is an important consideration for foreign 

 55 See Prasad and Ye (2012). 
53

investors, who typically like to invest in markets where they can easily execute large trades 

without concern that those trades may themselves move prices in an unfavorable direction.

Table 4-3. Stocks and Turnover of Government and Corporate Bonds: 

A Cross-Country Perspective

Government Corporate

Amount 

Outstanding Turnover Turnover Ratio

Amount 

Outstanding Turnover Turnover Ratio

U.S. 13,063 127,739 9.8 7,718 5,368 0.7

Japan 8,216 11,103 1.4 670 37 0.1

Euro area 8,126 - - 3,655 - -

China 3,515 1,885 0.5 1,570 425 0.3

Germany 1,356 5,919 4.4 267 - -

Sources: Statistical Abstract of the United States, Securities Industry and Financial Markets Association 

(SIFMA), European Central Bank, Bundesbank, The Federal Financial Supervisory Authority, 

AsianBondsOnline, CEIC data, Securities and Exchange Board of India, and author’s calculations

Notes: Data shown in this table are for 2014. The data shown here do not include debt securities issued by

monetary financial institutions such as central banks. Government bonds include both central and general 

government debt. The value of government and corporate bonds outstanding and turnover are expressed in 

billions of U.S. dollars. Corporate bonds for China, the euro area, Germany, and Japan include those issued 

by nonfinancial and financial corporations. 

China’s aspirations to make the RMB a global reserve currency rest in large part on the pace of 

development of its fixed-income markets. Reserve currency economies are expected to issue 

high-quality and creditworthy government debt or government-backed debt instruments that can 

serve to hedge against foreign investors’ domestic currency depreciation during a global 

downturn. The current level of government debt in China is relatively low compared with 

existing major reserve currency areas. While the low level of debt provides more credibility for 

the government’s fiscal and inflation control policies, the limited supply of safe and liquid RMBdenominated assets is a constraint on the RMB’s ascendancy to reserve currency status. The 

recent growth of China’s debt markets suggests that the pace of the country’s financial market 

development is consistent with its intention to gradually increase acceptance of its currency as an 

international currency.

4.5. Summary: Financial Markets Remain a Weak Link

China’s financial markets have improved in some respects during the last decade, but there are 

still significant gaps, especially in terms of achieving sufficiently large and liquid debt markets. 

More importantly, the structure and quality of debt markets will also need to be improved to 

fully prepare for a currency used widely in international financial transactions and reserve 

holdings. With relatively low external and government debt positions, China’s debt markets can 

in principle expand rapidly without serious threat to inflation credibility or vulnerability to 

external risks. Effective regulation of corporate debt markets is an important priority, so these 

markets can expand without generating financial instability. Moreover, to satisfy their demand 
54

for relatively safe RMB-denominated assets, foreign investors—both official and private—will 

eventually need to be given greater access to China’s debt markets if the RMB is to become a 

true international currency.

The main conclusion of this chapter is that China has made significant progress in many areas 

but still falls short along some key dimensions of financial market development. The 

government’s efforts to aggressively promote the RMB’s international role are likely to be 

impeded over the medium term by the weaknesses of China’s financial system. 

From a broader perspective, however, it is important to keep in mind that, during the past two 

years, the government has been making progress—slow and uneven in many ways, but progress 

nonetheless—on financial sector reforms that are essential for China to better manage its 

economy and allocate its massive pool of savings to more productive investment opportunities.

The government has fully freed up interest rates on bank deposits and loans (although the PBC 

still sets reference rates). The implicit backing of all bank deposits by the government has been 

replaced with an explicit deposit insurance system, exposing even state-owned banks to more 

market discipline since depositors are now more likely to pay attention to the financial condition 

of banks they keep their savings in. A great deal remains to be done to ensure the stability and 

resilience of China’s financial system. There are certainly many regulatory gaps that still exist in 

different parts of the financial system; in addition, rising levels of corporate debt and the 

proliferation of the shadow banking system all pose risks to financial stability. The government’s 

heavy-handed intervention in both the equity and currency markets to restore stability has hurt 

confidence and generated additional uncertainty about the true nature of these markets. 

The fundamental question that China’s policymakers face is whether they will back up their 

commitment to financial sector reforms with broader reforms that will truly free up markets and 

support them with a strong institutional foundation. Otherwise, the inherent contradictions in 

trying to free up markets while maintaining state control may cause well-intentioned reform 

efforts to backfire, simply creating more volatility and generating few of the intended benefits.
55

5. International Use of the RMB

This chapter provides a quantitative evaluation of the RMB’s rising prominence as an 

international currency. In the mid-2000s, China began to promote the international use of the 

RMB, but with its customary cautious and gradual approach. With its sophisticated financial 

markets, along with strong supervisory and other institutions, Hong Kong provided a perfect 

testing ground for these policy reforms. Meanwhile, its status as an international financial center 

means that Hong Kong could actively help build up the RMB’s role, at least in Asia. 

As early as 2004, personal RMB business had been initiated in Hong Kong by allowing residents 

there to open deposit accounts denominated in RMB. In 2007, China began to take a number of 

additional steps to promote the international use of its currency, in most cases using Hong Kong 

as the platform including:

• Permitting the settlement of trade transactions with RMB

• Easing restrictions on cross-border remittances of RMB for settlement

• Allowing the issuance of RMB-denominated bonds in Hong Kong and other offshore 

financial centers

• Permitting selected banks to offer offshore RMB deposit accounts

Given China’s rapidly expanding trade volumes, promoting greater use of the RMB in trade 

settlement was a logical first step in the currency’s internationalization process. In a relatively 

short period, cross-border trade settlement in the Chinese currency expanded rapidly. Figure 5-1 

shows that trade settlement in RMB was $1.72 trillion in the first quarter of 2015, amounting to 

roughly 23 percent of China’s trade. Virtually all of the trade settled using the RMB involves 

China. The rapid rise in the share of China’s trade settled using RMB came to a halt in early 

2014, which may be related to the lower appreciation pressures on the currency since that period. 
56

Figure 5-1. Settlement of China’s Foreign Trade in RMB

Sources: PBC, SAFE

Notes: The bars show the value of trade settlement in RMB (billions of RMB, left scale). The solid line 

shows the share of China’s trade settled in RMB (in percent, right scale). 

To support RMB settlement, the Hong Kong Interbank Market initiated an RMB settlement 

system in March 2006 in order to provide a variety of services such as check clearing, remittance 

processing, and bankcard payment services. RMB clearing transactions were virtually at zero 

until mid-2010, when financial institutions in Hong Kong were allowed to open RMBdenominated accounts. RMB activities in Hong Kong are supported by a sizable RMB liquidity 

pool, which is the largest outside mainland China. At the end of 2014, RMB customer deposits 

and certificates of deposit issued by banks in Hong Kong together amounted to over RMB 1.1 

trillion ($170 billion). RMB financing is also available in Hong Kong in the form of bank loans. 

The outstanding amount of RMB loans in Hong Kong was RMB 188 billion ($30 billion) at the 

end of 2014.56

Another major development is the rising issuance of RMB-denominated bonds, better known as 

dim sum bonds, in Hong Kong. The outstanding stock of these bonds had a value of RMB 381 

billion ($59 billion) at the end of 2014, making Hong Kong by far the largest RMB bond market 

outside the mainland. Other RMB bond markets include Singapore, Taiwan, and the United 

Kingdom. Figure 5-2 shows the stock of outstanding bonds, which grew more slowly in 2014 

than in previous years, reflecting that the issuance of new bonds has slowed. This slowdown 

might indicate shifting expectations about RMB appreciation. About 42 percent of the 

outstanding stock of RMB bonds at the end of 2014 was accounted for by mainland government 

agencies, banks, and enterprises. It is worth noting that about 40 percent of RMB bond issuers in 

Hong Kong are entities incorporated overseas (outside the mainland and Hong Kong). 

 56 Some of the figures in this paragraph and the next are taken from the Hong Kong Monetary Authority’s 

publication, “Hong Kong: The Premier Offshore RMB Business Centre,” April 2015. 

0% 

8% 

15% 

23% 

30% 

0 

450 

900 

1350 

1800 

2250 

2010Q1 2011Q1 2012Q1 2013Q1 2014Q1 2015Q1 

Trade Settlement in RMB (RMB bn) 

Share of Trade Settlement in RMB 
57

Multinational companies from countries such as Germany, South Korea, and the United States 

apparently view these bonds as an affordable way to raise RMB funds that can in principle then 

be used to fund investments and other operations in China. 

Figure 5-2. Dim Sum (RMB-Denominated) Bonds

Source: Hong Kong Monetary Authority RMB Booklet, April 2015

In October 2015, the PBC for the first time issued offshore one-year RMB bonds in London in 

the amount of RMB 5 billion (approximately $800 million). The PBC noted that this was its first 

ever offshore RMB bond issuance and that this would help promote the offshore use of the 

currency as well as cross-border trade and investment. Press reports indicate that China’s 

Ministry of Finance is preparing to issue longer-dated RMB bonds in London in the near 

future.57

With the initiation and rapid expansion of several elements of the offshore RMB market, the 

currency has been gaining a significant foothold in Asia’s trade and financial transactions. Since 

2012, the government has initiated a new and more potent set of measures to increase offshore 

RMB use. The remainder of this chapter describes one of the major developments since 2012—

the rising number of offshore RMB clearing centers. This is followed by a quantitative 

assessment of the RMB’s rising prominence as a payment currency and its somewhat more 

limited progress in international financial transactions.

 57 See “China completes first London debt sale,” Financial Times, October 20, 2015. 
58

5.1. Offshore Clearing Centers

The RMB’s broad international use will be determined to an important extent by how much 

RMB liquidity is available offshore and how many financial centers are authorized to serve as 

clearing centers for RMB transactions. The Chinese government has taken a number of measures 

in recent years to promote the RMB’s international use by increasing the number of international 

financial centers authorized to do RMB business and by making it easier to settle transactions 

abroad in RMB.

Table 5-1 shows that a total of 15 financial centers now serve as Chinese government-approved 

offshore centers for clearing RMB transactions. The list spans a wide geographic distribution of 

countries, with only five of them in Asia (Singapore, Taiwan, Thailand, South Korea, and 

Malaysia). Three major European financial centers—Frankfurt, London, and Paris—joined the 

list in 2014. Two Latin American countries—Chile and Argentina—are the latest additions. 

Japan and the United States are prominent absences. Given China’s strong interest in promoting 

the RMB’s international use, this is probably due to lack of interest from these two countries’ 

governments and regulatory agencies. 

Table 5-1. Recent Offshore RMB Clearing Arrangements

(excluding Hong Kong and Macao)

Country Date Signed

(Date of Bank Appt)

Bank Appointed Transaction

Amount

Share of

Payment

Value

Singapore July 6, 2012

(Feb 8, 2013)

ICBC 10 trillion+ ¥

(April 8, 2014)

6.9%

Taiwan Aug 31, 2012

(Dec 11, 2012)

Bank of China 3.1 trillion ¥

(May 2014)

2.6%

Germany Mar 28, 2014

(June 19, 2014)

Bank of China TBA 0.6%

Thailand Dec 22, 2014

(Jan 8, 2015)

ICBC (Thai) Public

Co. Ltd.

TBA <0.4%

United Kingdom Mar 31, 2014

(June 18, 2014)

China Construction

Bank

TBA 5.1%

Luxembourg June 28, 2014

(Sept 23, 2014)

ICBC Luxembourg TBA 0.6%

France June 28, 2014

(Sept 23, 2014)

Bank of China Paris TBA 1.1%

South Korea July 3, 2014

(July 4, 2014)

Bank of

Communications of

China

TBA 2.3%
59

Qatar Nov 3, 2014

(Nov 14, 2014)

ICBC (Qatar) TBA <0.4%

Malaysia Nov 10, 2014

(Jan 8, 2015)

Bank of China

(Malaysia) Berhad

TBA 0.4%

Australia Nov 17, 2014

(Nov 17, 2014)

Bank of China

(Sydney)

TBA 1.5%

Canada Nov 17, 2014

(Nov 17, 2014)

ICBC (Canada) TBA <0.4%

Switzerland Jan 21, 2015 TBA N/A <0.4%

Chile May 26, 2015 China Construction

Bank (Chile)

TBA <0.4%

Argentina Sep 17, 2015 TBA TBA <0.4%

Notes: Each offshore clearing center has only one clearing bank. The third column of the table shows

official RMB clearing banks. The shares of payment values are based on data from the SWIFT RMB

tracker as of July 2015 (SWIFT Institute, July 2015). In addition to the designated offshore clearing

centers listed in the table, two special RMB centers that were set up over a decade ago—Hong Kong

(December 2003) and Macao (September 2004)—account for 69.8 percent and 0.4 percent of payment

values, respectively. The United States, Japan, and the Netherlands are not offshore clearing centers but

are ranked among the top 15 countries, with their shares of payment values amounting to 2.68 percent, 0.4

percent, and 0.3 percent, respectively. 

5.2. The RMB’s Role as a Payment Currency

One indicator of the RMB’s rising international role is its evolution as a payment currency, i.e., a 

currency used for clearance and settlement of cross-border financial transactions. Data on the 

RMB’s role as a payment currency are based on information compiled and provided by the 

Society for Worldwide Interbank Financial Telecommunication (SWIFT). SWIFT provides a 

network that enables financial institutions worldwide to send and receive information about 

financial transactions in a standardized environment. While SWIFT transports financial 

messages, it does not perform clearing or settlement of transactions. Because financial 

institutions have multiple means to exchange information about their financial transactions, 

SWIFT statistics on financial flows do not represent complete market or industry statistics. 

Nevertheless, the majority of international interbank messages use the SWIFT network.

SWIFT data on the RMB measure primarily the number of financial institutions using the RMB 

for payments, both inbound and outbound, throughout the world. The data can also be used to 

show the share of the RMB in terms of the value of all payments transacted over the SWIFT 

network. Figure 5-3 shows that this share has risen significantly in recent years, from 0.3 percent 

at the end of 2011 to 2.8 percent by August 2015. In September 2015, the RMB’s share of global 

payments fell slightly to 2.5 percent, although the upward trend remains clear.
60

Figure 5-3. RMB as World Payment Currency by Value

(in percent)

Source: SWIFT Watch

Notes: The data shown represent the value of customer-initiated and institutional payments, in terms of 

both inbound and outbound traffic over the SWIFT network, that are denominated in RMB as a 

percentage of total payments over the SWIFT network.

While this share still seems relatively modest, it has vaulted the RMB from ranking 20th in 

importance at the end of 2012 to becoming the fifth most important payment currency by 

September 2015 (Figure 5-4). That leaves just four currencies—the U.S. dollar (43.6 percent), 

the euro (28.5 percent), the pound sterling (8.7 percent), and the Japanese yen (2.9 percent)—

ahead of the RMB by this metric. In August 2015, the RMB in fact briefly jumped ahead into 

fourth place ahead of the yen. Present trends of the RMB’s rising use as a payment currency 

suggest that it is likely the currency will regain this spot in the near future.

0 

0.5 

1 

1.5 

2 

2.5 

3 
61

Figure 5-4. RMB as World Payment Currency by Rank

Source: SWIFT Watch

Notes: The data shown in this figure represent the rank of the RMB in terms of the value of customerinitiated and institutional payments, in terms of both inbound and outbound traffic over the SWIFT 

network, that are denominated in RMB relative to other currencies.

Figure 5-5 shows which territories account for payment transactions in RMB. Hong Kong had 

the dominant share in 2012, accounting for about 80 percent of RMB transactions over the 

SWIFT network. By 2015, that share had declined to 70 percent, although Hong Kong still 

dominates in terms of these transactions. 

0 

5 

10 

15 

20 

25 
62

Figure 5-5. RMB Payments: Country Shares

(shares in percentage of world payments in RMB)

Source: SWIFT 

Notes: The data shown in this figure represent the value of customer-initiated and institutional payments, 

in terms of both inbound and outbound traffic over the SWIFT network, that are denominated in RMB as 

a percentage of total payments over the SWIFT network. The different sections of the bars show what 

shares of these payments are accounted for by Hong Kong, China, and all other countries. 

Figure 5-6 shows a more detailed breakdown of the top 15 countries in terms of the value of 

overall RMB payment transactions. Singapore and the United Kingdom account for 6.9 percent 

and 5.1 percent, respectively, while China itself accounts for less than 5 percent. Most of the 

countries on this list are also designated as RMB clearing centers. The United States is an 

important exception—it does not have a clearing center for RMB transactions but still accounted 

for nearly 3 percent of RMB payments over the SWIFT network.

0.0 

0.5 

1.0 

1.5 

2.0 

2.5 

Hong Kong China Other Countries 

27%	

3%	

70%	

14%	

6%	

80%	
63

Figure 5-6. RMB Payments: Top 15 Countries/Territories

Source: SWIFT

Notes: This figure shows which countries account for RMB-denominated payments, in terms of both 

inbound and outbound traffic, over the SWIFT network. 

While the SWIFT data on the RMB’s rising international role have attracted great interest, there 

are a few important caveats in this regard. First, SWIFT estimates its market share to be around 

80 percent of all cross-border payment flows in volume (correspondent banking); remaining 

transactions go through channels other than SWIFT. Second, SWIFT does not capture all intrainstitutional flows since financial institutions may use their own proprietary networks or systems.

Third, SWIFT does not capture a large share of domestic flows. For instance, transactions that 

are intermediated through the Fedwire Funds Service are not on SWIFT. Fourth, the financial 

flows (sender–receiver) track bank-to-bank activity rather than the underlying commercial flows. 

For instance, a commercial transaction between China and South Africa that is intermediated 

through a U.S. bank could involve two messages—one between South Africa and the United 

States, and the other between the United States and China. This could result in double counting 

of some financial transactions (relative to the value of the underlying commercial transactions).

Notwithstanding these caveats, the SWIFT data reveal the rising prominence of the RMB as an 

international payment currency, although it is still a long way from being a major payment

currency that can rival the U.S. dollar. 
64

5.3. Limited Use in International Financial Transactions

The pace of the internationalization of China’s currency depends on its use in international 

financial transactions as well. The choice of currency for denomination and settlement of trade 

flows is contingent on the extent to which that currency can also be used in international 

financial transactions. This section analyzes data on foreign exchange market turnover, 

derivatives markets, and currency denominations of international debt securities. A considerable 

portion of these data are taken from the Bank for International Settlements (BIS) Triennial Bank 

Survey. The most recent survey was conducted in 2014 and contains data for 2013.58

Foreign exchange market turnover is a good indicator of a currency’s potential for developing 

into a vehicle currency. As shown in Table 5-2, the RMB now accounts for over 2 percent (out of 

200 percent, as each transaction involves two currencies) of all turnover in foreign exchange 

markets. While this may seem like a small share, it represents a considerable increase over a 

relatively short period, especially for a currency that is not freely convertible. The U.S. dollar is 

dominant in this dimension, accounting for 87 percent of turnover in 2013. The four major 

reserve currencies (the dollar, the euro, the yen, and the pound sterling), along with the 

Australian dollar and Swiss franc, together account for 169 percent of total turnover. The shares 

of other major emerging markets’ currencies are all below 2 percent.

Table 5-2. Currency Distribution of Global Foreign Exchange Market 

Turnover 

(selected currencies, in percent)

2001 2004 2007 2010 2013

U.S. dollar 89.9 88.0 85.6 84.9 87.0

Euro 37.9 37.4 37.0 39.1 33.4

Japanese yen 23.5 20.8 17.2 19.0 23.0

Pound sterling 13.0 16.5 14.9 12.9 11.8

Australian dollar 4.3 6.0 6.6 7.6 8.6

Swiss franc 6.0 6.0 6.8 6.3 5.2

Indian rupee 0.2 0.3 0.7 1.0 1.0

Russian ruble 0.3 0.6 0.7 0.9 1.6

Chinese RMB 0.0 0.1 0.5 0.9 2.2

South African rand 0.9 0.7 0.9 0.7 1.1

Brazilian real 0.5 0.3 0.4 0.7 1.1

All currencies 200.0 200.0 200.0 200.0 200.0

Source: BIS Triennial Central Bank Survey

Notes: The percentage shares of individual currencies sum to 200 percent because

two currencies are involved in each transaction. Data are adjusted for local and 

cross-border inter-dealer double counting (i.e., “net-net” basis).

 58 See Prasad and Ye (2012) for further discussion of the concepts and data. 
65

In terms of the geographical distribution of foreign exchange turnover, however, China has the 

advantage of having Hong Kong as an important financial center for settling foreign exchange 

transactions (Table 5-3). Hong Kong accounts for 4 percent of global foreign exchange market 

turnover (compared with 41 percent for the United Kingdom and 19 percent for the United 

States). This leaves the RMB on a competitive footing, at least relative to other emerging market 

currencies in terms of attaining the role of an international currency. 

Table 5-3. Geographical Distribution of Global Foreign Exchange Market 

Turnover 

(selected economies; in percentages)

2001 2004 2007 2010 2013

United Kingdom 31.8 32.0 34.6 36.8 40.9

United States 16.0 19.1 17.4 17.9 18.9

Singapore 6.1 5.1 5.6 5.3 5.7

Japan 9.0 8.0 5.8 6.2 5.6

Hong Kong 4.0 4.1 4.2 4.7 4.1

Switzerland 4.5 3.3 5.9 4.9 3.2

Germany 5.4 4.6 2.4 2.2 1.7

Russia 0.6 1.1 1.2 0.8 0.9

China ... 0.0 0.2 0.4 0.7

India 0.2 0.3 0.9 0.5 0.5

Brazil 0.3 0.1 0.1 0.3 0.3

South Africa 0.6 0.4 0.3 0.3 0.3

Total 78.5 78.1 78.6 80.3 82.8

Source: BIS Triennial Central Bank Survey

Notes: Other countries with at least a 1 percent share include Australia, France, 

Canada, Denmark, and the Netherlands. An ellipsis indicates that data were not 

available for that year. Data are adjusted for local inter-dealer double counting (i.e.,

“net-gross” basis). Estimated coverage of the foreign exchange market ranged 

between 90 percent and 100 percent in most countries.

Overall, the spot and derivatives markets for trading in the RMB have progressed to a significant 

extent but still remain underdeveloped (see Table 5-4). China’s currency once took a relatively 

low share of spot transactions turnover among all major economies, but that has shifted over the 

period 2010–2013 (since the previous BIS Triennial Central Bank Survey that had data through

2010). The RMB’s foreign exchange derivatives trading volume, which was once far smaller 

than those of the major reserve currencies, has also improved. China also has a major presence in 

markets for commodity futures (not shown here). Based on the number of futures/options traded, 

three of China’s commodity futures exchanges are among the top 20 derivatives exchanges in the 

world. These data suggest that China has made some headway in promoting the international use 

of its currency. 
66

Table 5-4. Global Foreign Exchange Market Turnover: 

Currency and Instrument Distribution

(percentage shares of average daily turnover: April 2013)

Spot Outright 

forwards

Foreign 

exchange 

swaps

Currency 

swaps

Options, 

other 

instruments

U.S. dollar 36.3 12.6 43.6 1.1 6.3 

Euro 42.2 10.0 42.9 1.0 3.9 

Japanese yen 49.7 10.0 27.0 0.9 12.4 

Pound sterling 36.0 10.9 47.7 0.8 4.6 

Australian dollar 42.4 10.8 39.6 1.3 5.8 

Swiss franc 30.5 9.8 54.2 0.4 5.1 

South African rand 31.7 11.7 51.7 - 3.3 

Russian ruble 43.5 10.6 43.5 - 3.5 

Indian rupee 28.3 45.3 18.9 - 5.7 

Brazilian real 18.6 57.6 1.7 5.1 18.6 

Chinese RMB 28.3 23.3 33.3 0.8 14.2 

Source: BIS Triennial Central Bank Survey

Notes: This table shows, for each currency, the relative shares of its turnover in each of the five 

categories of global foreign exchange market shown in the column. Each row sums to 100. Data are 

adjusted for local and cross-border inter-dealer double counting (i.e., “net-net” basis). 

The RMB now leads other emerging market currencies in terms of its share of the turnover in 

global foreign exchange markets (Table 5-5). The U.S. dollar, the euro, and the Japanese yen 

together account for a substantial fraction of the total turnover in spot and derivatives markets. 

The Chinese RMB has made significant progress—especially in terms of the share of its turnover 

in spot, outright forwards, and foreign exchange swaps markets. Its share of global foreign 

exchange market turnover still remains modest but is larger than those of other major emerging 

markets. 
67

Table 5-5. Turnover in Global Foreign Exchange Markets, April 2013 

(daily averages in billions of U.S. dollars during April 2010)

Spot Outright 

forwards

Foreign

exchange

swaps

Currency 

swaps

Options 

sold

Options 

bought

Total 

options

Total 

foreign 

exchange

contracts

U.S. dollar 1,691 588 2,030 50 189 188 293 4,652

Euro 754 178 766 18 48 46 70 1,786

Japanese yen 612 123 332 11 94 99 153 1,231

Pound sterling 227 69 301 5 19 20 29 631

Australian dollar 196 50 183 6 19 19 27 462

Swiss franc 84 27 149 1 8 8 14 275

Chinese RMB 34 28 40 1 11 11 17 120

S. African rand 19 7 31 0 1 1 2 60

Russian ruble 37 9 37 0 2 2 3 85

Indian rupee 15 24 10 0 2 2 3 53

Brazilian real 11 34 1 3 8 7 11 59

Source: BIS Triennial Central Bank Survey 

The RMB’s presence in the interest rate derivatives market is also modest, accounting for 0.9 

percent of trades cleared through centralized counterparties and 0.2 percent of the notional value 

of such trades (Table 5-6, Panel A). For all trades, these shares for the RMB are lower, at 0.5 

percent and 0.1 percent, respectively (Table 5-6, Panel B). 
68

Table 5-6. Interest Rate Derivatives by Currency, 2012

A. Trades Cleared through Centralized Counterparty

Gross Notional Value Total Trade Count

USD billions Percent of total Trade count Percent of total

Euro 80,018 33.9 628,417 25.3

U.S. dollar 75,502 32.0 702,401 28.3

Japanese yen 29,271 12.4 267,440 10.8

Pound sterling 20,526 8.7 234,049 9.4

Swiss franc 2,652 1.1 32,221 1.3

S. African rand 1,792 0.8 30,080 1.2

Brazilian real 776 0.3 15,658 0.6

Indian rupee 742 0.3 43,097 1.7

Chinese RMB 435 0.2 22,417 0.9

Russian ruble 1,466 0.6 6,648 0.3

Share of total 213,180 90.3 1,982,428 79.8

Total 236,185 2,483,499 

B. All Trades

Gross Notional Value Total Trade Count

USD billions Percent of total Trade count Percent of total

Euro 172,596 34.8 1,103,212 25.6

U.S. dollar 172,099 34.7 1,320,501 30.7

Japanese yen 64,845 13.1 64,845 1.5

Pound sterling 42,325 8.5 425,289 9.9

Swiss franc 5,921 1.2 77,470 1.8

S. African rand 2,387 0.5 49,975 1.2

Brazilian real 775 0.2 15,658 0.4

Indian rupee 742 0.1 43,097 1.0

Chinese RMB 435 0.1 22,417 0.5

Russian ruble 132 0.0 6,648 0.2

Share of total 462,257 93.2 3,129,112 72.7

Total 495,889 4,302,569 

Source: Tri-Optima Trade Repository Report, 2012

Notes: CCP refers to any interest rate trade cleared through a central counterparty. It was calculated by 

adding the trade summary by currency for G14 and non-G14 dealers. Tri-Optima’s Interest Rate Trade 

Repository Report no longer publishes these data. The Depository Trust and Clearing Corporation now 

manages the data but does not make it available to the public.

Another indicator of the currency’s potential use in international financial transactions is the 

relative size of international debt securities (i.e., debt issued outside the home country) in various 

currencies of issuance. Table 5-7 shows that the existing reserve currencies clearly dominate, 

with the U.S. dollar and the euro accounting for 82 percent of outstanding international bonds 
69

and notes. The top five reserve currencies combined account for 95 percent of these instruments. 

Only a modest 0.5 percent of international debt is denominated in RMB. The same is true for 

other major emerging market currencies. 

Table 5-7. International Bonds and Notes Outstanding 

(selected currencies)

June 2015 

(USD billions)

Share 

(percent of total)

U.S. dollar 8,816 42.7

Euro 8,092 39.2

Pound sterling 1,988 9.6

Yen 402 1.9

Swiss franc 295 1.4

Chinese RMB 98 0.5

Brazilian real 37 0.2

South African rand 29 0.1

Russian ruble 21 0.1

Indian rupee 7 0.0

Source: BIS Quarterly Review, Detailed Statistical Annex, Table 13B, 

September 2015

Note: This table shows the breakdown of outstanding international debt 

securities by currency denomination. 

5.4. The China International Payment System

The interbank payment system serves as the basic infrastructure of financial markets as it is 

necessary for inter-bank funds transfer and currency clearing in most countries. Individual 

financial institutions can always find corresponding banks to fulfill their specific needs for funds 

transfer and payments. However, this is inefficient and costly, especially with the large volume 

of transactions occurring each day, many of them involving cross-border activities. The payment

system provides a central platform that helps clear interbank financial transactions in a 

standardized manner both domestically and internationally.

The domestic RMB payment system, called the China National Advanced Payment System 

(CNAPS), is not in line with international standards and its operation is limited by its 

incompatibility with foreign language codes. Hence, China has recently set up a new payment

system—the China International Payment System (CIPS)—organized more in line with 

internationally accepted standards, which is essential for facilitating cross-border RMB 

transactions, including trade and investment flows.

The main function of the CIPS is to provide clearing and payment services for financial 

institutions engaged in cross-border RMB and offshore RMB business. Phase One of the CIPS 

commenced operation on October 8, 2015. According to the PBC, the first phase will facilitate 
70

processing of cross-border RMB business; settlement of cross-border trade in goods and 

services; cross-border direct investment; cross-border financing; and fund transfers for individual 

customers. The operating hours cover the time zones of Africa, Asia, Europe, and Oceania, 

raising the accessibility of cross-border RMB settlements. Phase Two will expand to support 

other forms of cross-border movement of RMB and settlements of offshore funds. In cooperation 

with SWIFT, PBC will adopt ISO 20022 standards and support both Chinese and English. By 

addressing the limitations inherent in CNAPS, CIPS is likely to substantially reduce transaction 

costs and increase the international use of RMB. 

The first batch of direct participants in CIPS includes 19 banks: ICBC, ABC, BOC, CCB, Bank 

of Communications, China Merchants Bank, Pudong Development Bank, China Minsheng Bank, 

Industrial Bank, Pingan Bank, Huaxia Bank, HSBC Bank China, Citibank China, Standard 

Chartered Bank (China), DBS China, Deutsche Bank (China), BNP Paribas China, ANZ Bank 

(China), and Bank of East Asia. Moreover, 38 domestic banks and 138 overseas banks located in 

Africa, Asia, Europe, and Oceania are registered in the system as indirect participants.59

Questions remain as to how the new infrastructure will change the existing rules of the game. As 

noted earlier, PBC has designated 15 RMB offshore clearing centers (in addition to Hong Kong 

and Macao), along with the overseas branches of the major state-owned commercial banks 

(ICBC, BOC, and CCB) that are authorized to operate clearing business. In theory, the 

designated offshore centers will lose many of their privileges upon the establishment of the 

CIPS, as qualified financial institutions regardless of their location will have direct access to the 

onshore corresponding clearing banks or the central platform. In practice, however, CIPS is 

starting in a modest way with tests and trials among a limited number of designated institutions 

before gradually expanding its membership scope. It is also not clear if the existing overseas 

clearing branches of China’s state-owned banks in offshore clearing centers will be incorporated 

into the CIPS. It is likely that in practice CIPS will be a supplement to rather than a substitute for 

the existing offshore clearing arrangements.

The fact that the payment system serves as a public good does not mean it is always owned and 

run by the government. For example, there are two co-existing inter-bank payment systems in the 

United States, the Clearing House for Interbank Payment System (CHIPS) operated by the York 

Clearing House, an association of private banks, and the Federal Reserve Wire Network, 

commonly known as Fed Wire, a part of the Federal Reserve Bank System. Fed Wire has a 

domestic focus, providing transfer services to all banks within the Federal Reserve System, while 

CHIPS focuses on both domestic and international arenas, and has only 47 large financial 

institutions as members. Historically, CHIPS specialized in settling the dollar portion of foreign 

exchange transactions, although its focus has gradually shifted to the domestic market as well. It 

is believed that CIPS will be modeled along the lines of CHIPS, although control is likely to 

remain with the government. This will give the government access to information about 

payments processed through the system, allowing it to maintain oversight over cross-border 

financial transactions. 

 59 See “Milestone of RMB Internalization: RMB Cross-border Inter-bank Payment System Starts 

Operation,” PBC, October 14, 2015. 
71

It is worth emphasizing the distinctions between national payment systems and SWIFT. SWIFT 

is not a funds transfer system but rather an interbank communications system that was developed 

in 1973 for the purpose of providing a standardized, quicker, and more efficient means of sharing 

financial information between financial institutions around the world. So, in general, the national 

and international payment systems launched by particular countries do not per se act as 

substitutes for SWIFT, although the payment system does have to rely on SWIFT and has to be 

consistent with its standards. However, it is also possible that, while CIPS will adopt the same 

standards as SWIFT, it could be designed as a system for international RMB transactions 

independently of SWIFT. This would make it not only a funds transfer system but also a 

communication system.

Whichever form CIPS ultimately ends up taking, the main point is that it is the adoption of 

international standards that makes the new payment system a meaningful move in facilitating the 

international use of the RMB.
72

6. The RMB’s Role as a Reserve Currency

Attaining reserve currency status has intangible benefits, including prestige, as well as tangible 

ones. A country issuing a reserve currency earns seigniorage revenues from abroad—inflation 

reduces the value of foreign (and domestic) investors’ holdings of the currency—and provides 

easier access to cheap foreign financing of debt issued in the domestic currency. To the extent 

that this status results in a more extensive denomination of trade transactions in China’s own 

currency, domestic importers and exporters would face lower currency risk. The potential costs 

of having a reserve currency include reduced control of the currency’s external value and 

possibly a more volatile exchange rate. This status in principle entails a greater burden of 

responsibility because domestic monetary policy has more spillover effects to other economies.

The RMB’s prospects as a reserve currency will be influenced by these criteria:

• Economic size 

• Macroeconomic policies 

• Open capital account

• Flexible exchange rate 

• Financial market development 

This chapter evaluates how the RMB measures up on the first two criteria and then summarizes 

its progress towards reserve currency status. China’s progress on the latter three criteria has been 

covered in previous sections.

6.1. Economic Size

Some economists have argued that China’s sheer size and dynamism will result in its currency 

becoming a global reserve currency.60 As shown in Table 6-1, China has clearly become a major 

economic power, accounting for 13.4 percent of global GDP in 2014 based on nominal GDP 

measured at market exchange rates. At purchasing power parity (PPP) exchange rates, the 

Chinese economy is already slightly larger than the U.S. economy, accounting for 16.3 percent 

of global GDP. 

 60 See, for instance, Chen, Peng, and Shu (2009) and Subramanian (2011).
73

Table 6-1. Configuration of Global GDP: 2014

Nominal GDP GDP in PPP

USD billions Percent of 

world total USD billions Percent of world total

United States 17419 22.5 17419 16.1

Euro area 13391 17.3 - -

China 10380 13.4 17617 16.3

Japan 4616 6.0 4751 4.4

United Kingdom 2945 3.8 2549 2.4

Canada 1789 2.3 1592 1.5

Australia 1444 1.9 1095 1.0

Switzerland 712 0.9 473 0.4

Source: IMF World Economic Outlook Database, April 2015

Note: PPP refers to purchasing power parity adjusted measures of GDP.

While China’s growth over the last three decades is indeed awe inspiring, it is essential to keep 

in mind that China became big and influential before it became rich and, more importantly, 

before it had well-developed financial markets or broadly trusted public institutions. After all, if 

size was the main criterion, it is unlikely that a small country such as Switzerland, which has a 

GDP less than one-tenth that of China, would have one of the main reserve currencies in the 

world.

Another important criterion for achieving international or reserve currency status is the share of 

an economy in world trade and its trade interconnectedness with other economies. Although 

having large trade flows is neither a necessary nor sufficient condition for a country to have an 

international currency, it does boost the potential for the economy’s currency to serve as an 

invoice currency. This is an underlying implication of Krugman’s (1995) triangle model of 

currency invoicing—whereby economies are more likely to use the currency of the large nation, 

as measured by trade, due to economies of scale.

The value of China’s total trade is now only slightly lower than that of the two major economic 

areas—the euro zone and the United States (Table 6-2). China now accounts for 8.5 percent of 

world trade in goods and nonfactor services (Panel A), behind only the shares of the euro area 

and the United States (figures for the euro area include within-euro-area trade). When trade is 

measured on the basis of trade in goods alone, the same ranking of the top three holds, with 

China accounting for 10.5 percent of the world total. For an economy of its size, China also has a 

high ratio of total trade to GDP, higher than that of the euro area, the United States, and other 

key emerging markets. These indicators suggest China’s size and rising prominence in world 

trade. 
74

Table 6-2. Country Shares of World Trade 

(in percent)

A. Trade in Goods and Nonfactor Services

Exports Imports Total trade

Euro area 27.82 26.99 27.42

United States 9.91 12.49 8.62

China 9.98 9.32 8.48

Germany 7.48 6.65 5.77

Japan 3.64 4.34 3.22

United Kingdom 3.53 3.91 2.50

Russia 2.38 1.88 1.73

India 2.05 2.42 1.58

Switzerland 1.87 1.60 1.29

Brazil 1.12 1.40 0.98

South Africa 0.46 0.51 0.41

B. Trade in Goods

Exports Imports Total trade

Euro area 13.92 11.98 12.95

United States 8.76 12.50 10.65

China 11.51 9.46 10.48

Germany 8.00 6.26 7.12

Japan 3.75 4.21 3.98

United Kingdom 2.58 3.58 3.08

Russia 2.67 1.62 2.14

India 1.77 2.14 1.95

Switzerland 1.76 1.44 1.59

Brazil 1.20 1.22 1.21

South Africa 0.50 0.52 0.51

Sources: IMF’s International Financial Statistics, World Bank World Development Indicators, and 

Eurostat

Notes: Euro-area data include trade between countries within the area. 

In addition to trade volumes, another important criterion is the degree to which an economy is 

interconnected with other economies through trade linkages. This has implications for the 

incentives of traders in other countries to settle their transactions in the home country’s currency. 

On the basis of a variety of criteria, Errico and Massara (2011) find that, by 2010, China was the 

second-most interconnected country in terms of its trade flows, up from fifth in 2000. China is 

also ranked second in terms of the size of its trade, giving it the top rank in terms of overall 

systemic trade importance. The United States ranks first in size and 19th in terms of 
75

interconnectedness, giving it the rank of sixth in systemic trade importance.61 The study has not 

been updated, but China’s ranking is likely to have remained the same as its share of world trade 

has continued to rise.

6.2. Macroeconomic Policies

Macroeconomic policies that anchor long-run inflationary expectations and foster 

macroeconomic stability are typically important conditions for a reserve currency. China has a 

low level of explicit public debt relative to the major reserve currency economies. The level of 

central government debt is estimated to be about 17 percent of GDP in 2015. This is a positive

situation from the perspective of macroeconomic stability, even if it means limited availability of 

“safe” RMB-denominated assets. The IMF also calculates a measure of augmented debt, which 

includes various types of local government borrowing, including off-budget borrowing by Local 

Government Financing Vehicles (LGFVs) via bank loans, bonds, trust loans, and other funding 

sources. By this measure, China’s public debt to GDP is estimated to be about 57 percent of 

GDP in 2015, which would still be below the median public debt to GDP ratio among advanced 

economies.62 Moreover, China’s general government budget deficit has been quite small in 

recent years—it is forecast to be around 2.5 percent of GDP in 2011. In conjunction with the 

manageable level of public debt, this implies that China has room to counter domestic and 

external shocks using fiscal policy.63

China has had a relatively stable inflation rate in the recent past, as has been the case in most 

other major economies since 2000. Over the period 2000–2010, the standard deviations of annual 

consumer price index inflation in the advanced reserve currency economies were all around 1 

percent. During this period, the standard deviations of inflation in emerging markets were in the 

range of 3 to 4 percent, with China coming in lowest, with a standard deviation of 2 percent.64 In 

2014 and 2015, consumer price index inflation remained generally positive and under 2 percent. 

China’s track record in terms of the level and volatility of inflation should not impede its 

ascendancy to the status of having a global currency.

The reserve currency economies occupy diverse net international positions. The United States 

has a particularly large negative net foreign asset position, amounting to $6.7 trillion in the 

 61 The Netherlands has the highest rank in terms of interconnectedness; it is a small but very open 

economy with extensive trade linkages. The systemic trade importance ranks of some other countries are 

as follows: Germany (2), Korea (7), Japan (9), India (14), Russia (19), and Brazil (20).

62 The IMF refers to this figure for augmented debt as an upper bound of the government’s obligations. 

However, this figure does not seem to include estimates of contingent liabilities in the state-owned 

banking system, which could swell the government’s fiscal obligations. Reliable estimates of these 

contingent banking system liabilities are hard to come by.

63 According to a recent McKinsey report, China’s gross debt was 282 percent of GDP in 2014. This 

includes government debt (55 percent of GDP; similar to the IMF’s estimate) and debt of financial 

institutions’ (65 percent of GDP), nonfinancial corporates (125 percent of GDP), and households (38 

percent of GDP). For comparison, according to this report, U.S. gross debt in 2014 was 269 percent of 

GDP, accounted for mostly by government debt (89 percent of GDP) and household debt (77 percent of 

GDP). See “Debt (and Not Much) Develeraging,” McKinsey Global Institute, February 2015. 

64 See Prasad and Ye (2012). 
76

second quarter of 2015. The United Kingdom and the euro area as a whole also have negative net 

asset positions. By contrast, Germany, Japan, and Switzerland have positive net asset positions.

China, too, has a positive net asset position, amounting to nearly $1.5 trillion in the first half of 

2015.65 This diversity suggests that the signs of the net positions are themselves not crucial for 

reserve currency status. In other words, it is not essential for a country to run persistent current 

account deficits, as suggested by the Triffin dilemma, for its currency to attain reserve currency 

status. In fact, the average current account balance to GDP ratio over the period 2000–2007 was 

positive (or, in the case of the euro zone, essentially zero) for all reserve currency economies 

except the United Kingdom and the United States.

66

6.3. A Summary of China’s Progress on Traditional Reserve Currency Criteria

This section builds on the prior analysis to discuss the relative importance of each criterion for 

reserve currency status mentioned earlier and summarizes how China measures up. 

• Economic size: A country’s size and its shares of global trade and finance are important, 

but not crucial, determinants of the status of its reserve currency. China now accounts for 

13 percent of world gross domestic product (16 percent if measured by PPP rather than 

market exchange rates) and 9 percent of world trade. In 2014, it is estimated to have 

accounted for about one-third of world GDP growth. 

• Macroeconomic policies: Investors in a country’s sovereign assets must have faith in its 

commitment to low inflation and sustainable levels of public debt so the value of the 

currency is not in danger of being eroded. China has a lower ratio of explicit public debt 

to GDP than most major reserve currency economies and has maintained moderate 

inflation in recent years.

• Open capital account: Reserves must be acceptable as payments to a country’s trade and 

financial partners, which requires that the currency be easily tradable in global financial 

markets. This is difficult if a country imposes restrictions on capital flows and if its 

foreign exchange markets are thin and subject to direct control by the government. China 

is gradually and selectively easing restrictions on inflows and outflows. The capital 

account has become increasingly open in de facto terms, but extensive capital controls 

remain in place.

• Flexible exchange rate: Reserve currencies are typically traded freely, and their external 

value is market determined, although this does not preclude occasional intervention by 

the country’s central bank in foreign exchange markets. China has increased the 

flexibility of the exchange rate and permitted market forces to play a bigger role in 

foreign exchange markets. Despite these changes, China still has a closely managed 

exchange rate, which will become increasingly hard to manage as the capital account 

becomes more open.

 65 Data on international investment positions taken from IMF and CEIC. 

66 See Prasad and Ye (2012) and Prasad (2014) for more details.
77

• Financial market development: A country issuing a reserve currency needs broad, deep,

and liquid financial markets for international investors to have access to a wide array of 

financial assets denominated in its currency. China has relatively shallow government 

and corporate bond markets with low trading volumes, and a volatile stock market. 

While China measures up favorably in the first four areas, it still lags the major reserve currency 

economies by several measures of financial market development.

67 Despite its underdeveloped 

financial markets, however, China is trying to create a new playbook for its currency. Indeed, the 

RMB is already making its presence felt on the international stage, in part as the result of policy 

actions by the Chinese government and in part because of the sheer size and growing role of 

China in international trade and finance.

6.4. Swap Arrangements

Since 2009, the PBC has moved aggressively to establish bilateral swap arrangements with other 

central banks in order to facilitate and expand the use of the RMB in international trade and 

financial transactions. China had in fact established swap lines with many Asian central banks 

even before it started to actively promote the international use of its currency. Most of these were 

dollar–RMB swaps under which China would provide U.S. dollars in exchange for the local 

currency of the counterparty economy. In other words, the foreign exchange reserves of 

economies like China would often serve as an additional credit line facility if the counterparty 

economy were to face a liquidity crunch due to a balance of payments or financial crisis.

There is one crucial difference between the earlier swap arrangements and those the PBC has 

signed since 2009. Every one of the swaps in place now operates in terms of local currencies—

that is, the PBC commits to exchange other central banks’ currencies for RMB. By September 

2015, 34 central banks had signed such local currency swap arrangements with the PBC. The list 

of central banks and the maximum amounts of the arrangements are listed in Table 6-3. Eager to 

expand its RMB business and with the goal of making London a major center for RMBdenominated activity, by early 2013 even the Bank of England had signed such a swap line, 

making it the first G-7 central bank to sign one with the PBC. A number of other advanced 

economy central banks have also signed swap arrangements with the PBC.

The total amount that could be drawn by the 34 participating swap arrangements amounts to the 

equivalent of roughly half a trillion dollars, clearly a sizable amount. The largest one is with the 

Hong Kong Monetary Authority, for $63 billion. The PBC’s arrangements with the Bank of 

Korea, the Monetary Authority of Singapore, and the European Central Bank are in the range of 

$47 billion to $56 billion. 

 67 Angeloni et al. (2011) note that, in addition to strong financial markets, a reserve currency should be 

backed up by (1) the reliability of rules and institutions, (2) the quality and predictability of fiscal and 

monetary policies, (3) the ability of policymakers to respond to unexpected shocks, and (4) political 

cohesion. Some authors also argue that network externalities are important as they generate economies of 

scale and scope. See, for instance, Chinn and Frankel (2007). There is related empirical evidence of 

strong persistence effects in international investment patterns. See Appendix C of the report, “The 

International Role of The Euro,” July 2013. Frankfurt, Germany: European Central Bank.
78

Table 6-3. Central Bank Swap Arrangements with People’s Bank of China,

December 2008–September 2015

Bank Date Amount

(billion

RMB)

USD

equivalent

(billion)

1. Bank of Korea December 12, 2008 180 28.2

October 26, 2014 360 56.4

2. Hong Kong Monetary Authority January 20, 2009 200 31.3

November 27, 2014 400 62.7

3. Bank Negara Malaysia February 8, 2009 80 12.5

February 8, 2012 180 28.2

April 18, 2015 180 28.2

4. National Bank of the Republic of

Belarus

March 11, 2009 20 3.1

May 11, 2015 7 1.1

5. Bank Indonesia March 23, 2009 100 15.7

October 1, 2013 100 15.7

6. Central Bank of Argentina April 2, 2009 70 11.0

July 18, 2014 70 11.0

7. Central Bank of Iceland June 9, 2010 3.5 0.5

October 14, 2013 3.5 0.5

8. Monetary Authority of Singapore July 23, 2010 150 23.5

March 7, 2013 300 47.0

9. Reserve Bank of New Zealand April 18, 2011 25 3.9

May 22, 2014 25 3.9
79

10. Central Bank of the Republic of

Uzbekistan

April 19, 2011 0.7 0.1

11. Bank of Mongolia April 19, 2011 5 0.8

March 20, 2012 10 1.6

August 21, 2014 15 2.4

12. National Bank of Kazakhstan June 13, 2011 7 1.1

December 14, 2014 7 1.1

13. Bank of Thailand December 22, 2011 70 11.0

December 22, 2014 70 11.0

14. State Bank of Pakistan December 23, 2011 10 1.6

15. Central Bank of the United Arab

Emirates

January 17, 2012 35 5.5

16. Central Bank of the Republic of

Turkey

February 21, 2012 10 1.6

17. Reserve Bank of Australia March 22, 2012 200 31.3

April 8, 2015 200 31.3

18. National Bank of Ukraine June 26, 2012 15 2.4

19. Banco Central do Brazil March 26, 2013 190 29.8

20. Bank of England June 22, 2013 200 31.3

21. Central Bank of Hungary September 9, 2013 10 1.6

22. Bank of Albania September 12, 2013 2 0.3

23. European Central Bank October 10, 2013 350 54.9

24. Swiss National Bank July 21, 2014 150 23.5

25. Central Bank of Sri Lanka September 16, 2014 10 1.6

26. Central Bank of Russian Federation October 13, 2014 150 23.5

27. Qatar Central Bank November 3, 2014 35 5.5

28. Bank of Canada November 18, 2014 200 31.3
80

29. Nepal Rastra Bank December 25, 2014 Unknown Unknown

30. Central Bank of Suriname March 18, 2015 1 0.2

31. Central Bank of Armenia March 30, 2015 1 0.2

32. South African Reserve Bank April 10, 2015 30 4.7

33. Central Bank of Chile May 25, 2015 22 3.4

34. National Bank of Tajikistan September 7, 2015 3 0.5

Total Amount 3,162 495.8

Sources: PBC and other participating central banks

Notes: The U.S. dollar equivalent amounts are based on the September 9, 2015 exchange rate of 6.38 

RMB per dollar. The table shows only the dates of the initial arrangement and the latest arrangement (if 

the initial arrangement has been renewed). Intermediate renewals (for instance, the Bank of Korea’s and 

Hong Kong Monetary Authority’s renewals in 2011) are not shown. 

China’s bilateral swap lines with foreign central banks directly support the RMB’s greater 

international use. But the amounts involved in these bilateral agreements have been relatively 

small so far. The modest amounts notwithstanding, the PBC is clearly making an active effort to 

make the central banks of a broad group of economies comfortable and familiar with RMBdenominated instruments and financial facilities. 

6.4. RMB’s Appearance in Reserve Portfolios

Another interesting development is that, despite its lack of convertibility, the RMB is already 

beginning to play a modest role in a few central banks’ reserve portfolios.68 Chile, Malaysia, and 

Nigeria are widely believed to have pioneered this trend, starting in the second half of 2011. The 

Central Bank of Nigeria issued a statement on September 5, 2011, announcing that it “has 

finalized arrangements to diversify its external reserves holdings by including the Chinese RMB

(RMB) to the existing currency mix of United States dollars (USD), the euro (EUR) and the 

British pound sterling (GBP).”69 Furthermore, Chile’s internally managed Central Bank 

investment portfolio now has 3 percent of its assets allocated to RMB-denominated instruments, 

according to its September 2015 Monetary Policy Report.

Official statements and other accounts suggest that a number of other central banks also have or 

are considering adding RMB assets to their reserve portfolios. In addition to the three countries 

mentioned above, the list includes Austria, Australia, Pakistan, South Africa, Switzerland, 

Tanzania, Russia, and the United Kingdom. Most of the countries that are acquiring RMB for 

 68 Foreign central banks that want to buy Chinese bonds for their reserve portfolios have to get permission 

from the Chinese government through the QFII scheme. Sovereign wealth funds have to do the same. 

Responding to strong demand for higher access limits, in December 2012, SAFE removed the ceiling on 

inward investments by sovereign wealth funds, central banks, and monetary authorities.

69“Nigeria Approves Inclusion of Chinese RMB in External Reserves,” Central Bank of Nigeria Press 

Release, September 5, 2011.
81

their reserve portfolios or whose central banks have signed bilateral local currency swap 

arrangements with the PBC tend to have strong trading relationships with China. Hence, for 

these countries, access to RMB liquidity may be useful in facilitating trade transactions in 

addition to providing the benefit of portfolio diversification.

70

The IMF estimates that in 2014, about 1.1 percent of official foreign currency assets were held in 

RMB, up from 0.7 percent in 2013.71 This estimation is based on data from about 38 countries 

(not identified by the IMF), which reported that they held some RMB-denominated assets in 

their official reserve portfolios (in 2013 the number of reporting countries was 27). This puts the 

RMB in the seventh spot in terms of the identified composition of official foreign currency 

assets. The top six are the U.S. dollar (64 percent in 2014, 127 reporting countries), the euro (21 

percent), the British pound sterling (4 percent), the Japanese yen (3 percent), the Australian 

dollar (2 percent), and the Canadian dollar (2 percent). The RMB’s share is larger than those of 

the Swiss franc, the New Zealand dollar, and the Swedish krona, each of which accounts for 0.2 

percent.

The RMB’s progress is modest but the trajectory of its rise is unmistakable. The gains the RMB

has made so far are symbolically important in signaling the shift in perception of the RMB’s 

stability and its future role in the international monetary system. The apparent high degree of 

interest on the part of so many countries—small and large, within and outside Asia—to develop 

bilateral financial arrangements with China is striking.

One recent bilateral arrangement that is likely to influence finance in Asia is the pact that China 

and Japan signed in December 2011 to promote the use of their currencies for bilateral trade and 

investment flows.72 Bilateral trade and financial flows between these economies are still 

relatively modest, which implies that, even if all of these transactions are currently settled in 

dollars and will eventually be settled in the two countries’ currencies, the effect on switching 

from dollar-intermediated transactions would still be relatively modest at the global level. Over 

time, the effects could be larger, especially because the decline in currency transaction costs and 

exchange rate uncertainty could boost trade and financial flows between the two countries. China 

has also given permission for Japan’s Bank for International Cooperation to issue an RMBdenominated bond, while Japan has indicated that it will buy some Chinese government bonds, 

presumably to add to its reserve portfolio. Moreover, the arrangement is likely to serve as a 

template for other such bilateral arrangements between China and other countries in Asia.

 70 See Prasad (2014) for more details. 

71 See IMF, 2015.

72 For details on the China–Japan agreement, see “Enhanced Cooperation for Financial Markets 

Development between China and Japan.” People’s Bank of China Press Release. December 25, 2011. 
82

7. Implications of the RMB’s Inclusion in the IMF’S SDR Basket

The IMF’s Special Drawing Rights (SDRs) is an international reserve asset created by the 

institution in 1969. Since 2001, its value has been based on a basket of four reserve currencies—

the U.S. dollar, the euro, the Japanese yen and the pound sterling. On November 30, 2015, the 

IMF executive board voted to expand the SDR basket to include the RMB. The new basket will 

become effective in October 2016.

The SDR is neither a currency nor a claim on the IMF but serves as a potential claim on the 

freely usable currencies of IMF members. SDRs are distributed among IMF members on the 

basis of their quotas at their institutions. The stock of SDRs now stands at roughly $280 billion.73

SDRs can in principle be exchanged for “freely usable” currencies but cannot be used directly in 

private transactions. This means that increasing the stock of SDRs does not increase the total 

liquidity of the global monetary system unless a substitution account is used. But such 

substitution accounts that would result in the net creation of global liquidity via SDR issuance 

may not be practical, in part because SDRs are not backed by a global central bank and have no 

support from a fiscal authority.74

The RMB’s inclusion in the SDR basket with a weight of 10.9 percent is an important symbol of 

the currency’s ascendancy in global finance as it provides the currency with the IMF’s 

imprimatur as an official reserve currency. This chapter discusses the process that led to the 

RMB’s inclusion in the SDR basket and then reviews the implications of the IMF’s decision.

7.1. How the RMB Staked Its Claim for SDR Inclusion

Technically, the SDR basket consists of the major currencies that are (i) issued by IMF members 

(or monetary unions that include IMF members) that are the largest exporters and (ii) have been 

determined by the IMF to be “freely usable.” The latter condition was added as a formal criterion 

only in 2000 and is clearly open to interpretation. The IMF’s operational definition of a freely 

usable currency requires that it be (i) widely used to make payments for international 

transactions and (ii) widely traded in the principal exchange markets. That is, a freely usable 

currency is one that is liquid, convertible, and used for the settlement of international 

transactions. The objective of the freely usable currency concept in the context of IMF financing 

is to ensure that a member purchasing another member’s currency under an IMF arrangement 

will be able to use it, directly or indirectly, to meet its balance of payments needs.

In March 2009, PBC Governor Zhou Xiaochuan issued a paper, “Reform the International 

Monetary System,” on the PBC’s website.75 The paper laid out the case for SDRs to play a more 

prominent role in global finance and suggested that the composition of the SDR needed to keep 

up with changing times by incorporating the currencies of the major emerging market 

economies. The proposal was seen as a signal that China was staking its claim to have the 

 73 This is based on a stock of about 204 billion SDRs converted to U.S. dollars at the December 4, 2015 

exchange rate of 0.72 SDRs per $1. 

74 See Obstfeld (2011).

75 See Zhou (2009).
83

RMB’s global importance recognized by its inclusion in the exclusive group of currencies in the 

SDR basket.

The IMF’s position in 2010 was clear and summarized as follows in a report on its Executive 

Board’s discussion of the matter: 

Directors noted that although China has become the third-largest exporter of goods and 

services on a five-year average basis and has taken steps to facilitate international use of 

its currency, the Chinese RMB does not currently meet the criteria to be a freely usable 

currency and it would therefore not be included in the SDR basket at this time. Directors 

urged that this issue be kept under review in light of developments.76

Thus, it appeared that the IMF intended to apply the “freely usable” criterion strictly.

By 2011, the winds had shifted. There was considerable discussion that year about a proposal to 

include the RMB in the basket of currencies that constitute the SDR. The French government, 

during its presidency of the G-20 in 2011, promoted this proposal at several venues, viewing it as 

an important component of the reform of the international monetary system. At a G-20 

Conference in Nanjing in March 2011, French president Nicolas Sarkozy made the following 

statement: 

Isn’t it the time today to reach agreement on the timetable for enlarging the basket of 

SDRs to include new emerging currencies, such as the [RMB]? Who could deny the 

major role the [RMB] plays in the international monetary system? Tribute is thus paid to 

the economic power and the political power of China, a major monetary power.77

The communiqué issued at the conclusion of the November 2011 G-20 Summit in Cannes 

contained this language:

We agreed that the SDR basket composition should continue to reflect the role of 

currencies in the global trading and financial system and be adjusted over time to reflect 

currencies’ changing role and characteristics. The SDR composition assessment should 

be based on existing criteria, and we ask the IMF to further clarify them. A broader SDR 

basket will be an important determinant of its attractiveness, and in turn influence its role 

as a global reserve asset. This will serve as a reference for appropriate reforms. We look 

forward to reviewing the composition of the SDR basket in 2015, and earlier if 

warranted, as currencies meet the criteria, and call for further analytical work of the IMF 

in this regard, including on potential evolution.78

 76 “IMF Executive Board Completes the 2010 Review of SDR Valuation,” IMF Public Information 

Notice 10/149. 77 See “Address by Nicolas Sarkozy, President of the French Republic: Opening of the G20 Seminar on 

Reform of the International Monetary System,” G20 Information Center, University of Toronto, March 

31, 2011. 

78 See “Cannes Summit Final Declaration” G20 Information Center, University of Toronto, November 4, 

2011.
84

During his final press conference at the conclusion of that summit, Sarkozy was more explicit: 

“The [RMB] is a clear candidate [for inclusion in the SDR basket], given China’s commitment—

which I noted with satisfaction—to gradual convertibility.”

79

China itself had been more circumspect about the prospects of expanding the SDR basket. The 

deputy governor of the PBC (and also the head of SAFE), Yi Gang, urged the IMF to conduct 

more research into a shadow SDR and argued that “the IMF should consider including currencies 

of the BRICS [Brazil, Russia, India, China and South Africa—the world’s largest fast-growing 

emerging economies] countries and other emerging economies when it next reviews its SDR

system by 2015.” But Yi was also quoted as saying that “China is in no hurry as the SDR has so 

far been only a symbolic currency basket.”80

In November 2011, the IMF proposed the following indicators for evaluating a currency’s 

potential for inclusion in the SDR basket: (i) volume of transactions in foreign exchange spot 

markets; (ii) volume of transactions in foreign exchange derivatives markets and over-thecounter derivatives; (iii) existence of an appropriate market-based interest rate instrument; and 

(iv) currency composition of official reserve holdings.81

On August 4, 2015, the IMF released a report summarizing the approach for reviewing the 

composition and valuation of the SDR. The report noted that China met the gateway export 

criterion even at the time of the previous review in 2010 but that the RMB was not judged to be 

freely usable at the time. The report also noted that the RMB was by now “exhibiting a 

significant degree of international use and trading,” although at a level below those of the other 

four freely usable currencies that then constituted the SDR basket.82

The report then summarized the requirements for the RMB’s inclusion in the SDR basket: 

Availability of representative market-based exchange and interest rates is essential for the 

proper functioning of the SDR basket and the Fund’s financial operations, and the ability 

to hedge SDR-denominated positions is important to many Fund members and other SDR 

users. Restrictions on access to onshore markets pose difficulties in these areas, although 

some potential mitigating measures have been identified and the Chinese authorities have 

begun to implement such measures.83

The paper also discussed a possible extension of the current SDR valuation basket for a period of 

nine months to September 30, 2016, without prejudging the timing and outcome of the review, 

 79 See “G20 summit – Press conference given by Nicolas Sarkozy, President of the Republic,” November 

4, 2011. http://www.ambafrance-uk.org/President-Sarkozy-s-G20-summit

80 “China FX Head Proposes Adding BRICS Currencies to SDR,” Reuters, May 5, 2011. 

81 The documents summarizing the IMF’s official positions are: “IMF Executive Board Completes the 

2010 Review of SDR Valuation.” IMF Public Information Notice 10/149; “IMF Executive Board 

Discusses Criteria for Broadening the SDR Currency Basket.” IMF Public Information Notice 11/137. 

For more details on the underlying analysis, see “Criteria for Broadening the SDR Currency Basket.” 

IMF, September 2011.

82 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 

83 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 
85

which would have to be concluded by the end of calendar year 2015. The reason given was that 

introducing a new basket on the first trading day of the new year would expose SDR users to 

increased risks and costs. A longer lag would help reduce uncertainty for SDR users and 

facilitate continued smooth SDR-related operations.84 This proposal was approved by the IMF’s 

executive board on August 20, 2015. This approval was misinterpreted in some media reports as 

a delay in the deadline for the IMF’s review of the composition of the SDR basket.85

The widely traded assessment considers whether a member can transact a sizable amount of the 

currency at any time with the reasonable assurance that the market for that currency has 

sufficient depth so that no appreciable change in the exchange rate will occur. While aggregate 

foreign exchange market turnover is generally correlated with a market’s depth, breadth, and 

resilience, other indicators of the extent of usage in international markets is relevant as well. The 

RMB’s share of foreign exchange turnover has increased substantially, albeit from a low base. A 

broad range of other indicators also shows increasing international use of the RMB, although 

again from a low base (the list includes official foreign exchange reserves, international banking 

liabilities, stock and issuance of international debt liabilities, SWIFT cross-border payments, and 

SWIFT trade finance).

In applying the “widely traded” criterion, a determination is required as to what constitutes the 

“principal exchange markets.” Trading activity now occurs virtually around the clock, with a 

large share of transactions either through electronic trading platforms or using prices set with 

reference to them. Nonetheless, market activity and trading volumes remain closely tied to the 

business hours of major financial centers. In this context, “principal exchange markets” are best 

understood in terms of three broad time zones—corresponding roughly to the Asian, European, 

and North American market hours—rather than geographical market locations. In light of the 

requirement for a currency to be widely traded in multiple, but not necessarily all, principal 

markets, this could lend itself to the interpretation that members need to be reasonably assured of 

sufficient market depth in at least two of the three time zones.

The report noted that deviations between the offshore (CNH) and onshore (CNY) RMB 

exchange rates raised potential operational issues. Deviations between the two rates imply that 

the CNH cannot be a perfect hedge for CNY-based exposures.86 This had become a significant 

concern in the aftermath of the August 11, 2015 exchange rate move, which led to a sizable gap 

between the two rates (see the discussion in Chapter 3). The report noted that further 

liberalization of cross-border capital flows would help to reduce CNY–CNH divergences in the 

future.87

Availability of an appropriate interest rate instrument for the SDR basket was another key 

operational requirement. An assessment of a range of money-market interest rates suggested that 

 84 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 

85 IMF Press Release No. 15/384 “IMF Executive Board Approves Extension of Current SDR Currency 

Basket Until September 30, 2016,” August 19, 2015. For an example of a press report that misinterpreted 

this release, see “China was just dealt a major blow to the renminbi,” Business Insider Australia, August 

19, 2015. 

86 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 

87 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 
86

the three-month sovereign yield, which is published daily by the China Central Depository and 

Clearing Company (CCDC), was a potentially suitable candidate according to the IMF.

Giving members the ability to hedge their SDR-valued positions was also regarded as important. 

The onshore and offshore markets already trade interest rate and exchange rate forwards and 

swaps, repos, cross-currency swaps, and some options. But the report noted that capital controls 

have constrained onshore liquidity and activity at longer tenors. The report states that the 

authorities have been easing restrictions on access to onshore markets, which should facilitate 

hedging and other operations by IMF members and other SDR users.88

One important point is that full currency convertibility (i.e., a fully open capital account) is not 

regarded as either a necessary or sufficient condition for satisfying the free usability criterion. 

The report stated that a “currency may be widely used and widely traded even if the issuing 

member retains some restrictions . . . [but there needs to be] sufficient liberalization within the 

market in question to ensure that members who may receive financing from the Fund have 

adequate access to this market.”89 Moreover, the report made clear that many of the necessary 

conditions—convergence of the onshore and offshore exchange rates, availability of hedging 

instruments, and foreign exchange market liquidity—would all be easier to meet if capital 

account restrictions were liberalized.90

The overall assessment of this issue by the report was as follows: 

On the operational side, a number of issues would need to be resolved if the RMB were 

included in the SDR basket. Suitable exchange rates for SDR valuation and for the 

RMB/SDR exchange rate for Fund operations appear to be available, and potential 

operational difficulties arising from divergences between offshore and onshore exchange 

rates could be gradually mitigated by increasing investor access to the onshore market. 

Member access to the onshore market is required if CNY rates are used in the context of 

Fund operations and might be needed to secure adequate depth in FX markets. The threemonth sovereign yield could potentially be a suitable interest rate instrument for SDR 

basket inclusion, but further analysis is needed to verify that it is appropriate for this 

purpose. Similarly, hedging instruments are becoming increasingly available. The PBC 

has recently announced a package of reforms in these areas and staff is assessing whether 

they ensure sufficient access to the onshore markets for members and SDR users. The 

authorities are working closely with staff on outstanding issues in this area.91

The report concluded with an intriguing paragraph that speaks for itself:

The ultimate assessment by the Board will involve a significant element of judgment. The 

rapidly changing nature of RMB usage in the world trade and financial system poses 

challenges for the assessment. Judgment will have to be applied, including on the 

 88 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 

89 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 

90 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 

91 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 
87

importance of the various indicators and their proximity to the freely usable concept.92

7.3. The Decision and Its Implications

On November 13, 2015, Ms. Christine Lagarde, managing director of the IMF, issued the 

following statement:

The staff of the IMF has today issued a paper to the Executive Board on the quinquennial 

review of the SDR. A key focus of the Board review is whether the Chinese renminbi 

(RMB), which continues to meet the export criterion for inclusion in the SDR basket, also 

meets the other existing criterion, that the currency be “freely usable”, which is defined 

as being “widely used” for international transactions and “widely traded” in the principal 

foreign exchange markets. In the paper, IMF staff assesses that the RMB meets the 

requirements to be a “freely usable” currency and, accordingly, the staff proposes that the 

Executive Board determine the RMB to be freely usable and include it in the SDR basket 

as a fifth currency, along with the British pound, euro, Japanese yen, and the U.S. dollar. 

The staff also finds that the Chinese authorities have addressed all remaining operational 

issues identified in an initial staff analysis submitted to the Executive Board in July. I 

support the staff’s findings. The decision, of course, on whether the RMB should be 

included in the SDR basket rests with the IMF’s Executive Board.93

The U.S. Treasury signaled its support for the IMF staff’s position. On its web site, it noted that,

at a meeting with senior Chinese officials, “Secretary Lew reiterated that the United States 

intends to support the renminbi’s inclusion in the Special Drawing Rights basket provided the 

currency meets the International Monetary Fund’s existing criteria, and the United States is 

reviewing the IMF’s paper in that light.” 94

On November 30, 2015, the IMF executive board announced its decision to incorporate the RMB 

into the SDR basket with effect from October 1, 2016.95 The IMF also changed the formula used 

to calculate the shares of currencies in the SDR basket (the shares have to sum up to 100). The 

new formula is meant to better reflect the rising importance of cross-border financial flows in 

addition to trade flows. The formula assigns equal weight to exports and a financial indicator, 

reflecting a country’s importance in global trade and the currency’s importance in global 

financial markets, respectively. The financial indicator is a composite variable that assigns a 50 

percent weight to the share of reserves denominated in that currency, a 25 percent weight to 

 92 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015. 

93 IMF Press Release No. 15/513, November 13, 2015.

94 U.S. Department of the Treasury. Readout from a Treasury Spokesperson of Secretary Lew’s Meeting 

with Chinese Vice Premier Wang Yang and Finance Minister Lou Jiwei at the G-20 Leaders Summit in 

Antalya. November 15, 2015. 

95 “IMF’s Executive Board Completes Review of SDR Basket, Includes Chinese Renminbi,” IMF, 

November 30, 2015. 
88

foreign exchange turnover accounted for by that currency, and a 25 percent weight to the sum of 

international banking liabilities and international debt securities denominated in that currency.

96

Under the new formula, the weights of the SDR currencies are as follows: 41.7 percent for the 

U.S. dollar; 30.9 percent for the euro; 10.9 percent for the RMB; 8.3 percent for the Japanese 

yen; and 8.1 percent for the pound sterling. The new basket of currencies with these weights will 

take effect on October 1, 2016. Interestingly, the U.S. dollar’s share, which was 41.9 percent in 

the previous SDR basket, was essentially unchanged while the shares of the other three 

currencies fell significantly compared with their shares in the previous basket.

The IMF’s decision is an important validation of China’s efforts over the past year to liberalize 

financial markets, open up its capital account, and allow the RMB’s value to be determined to a 

greater extent by market forces. Progress in all of these areas has been slow and uneven as 

described in earlier chapters, but in a relative sense these reforms have outstripped those in other 

areas such as state-owned enterprise reform, liberalization of the services sector, and other 

reforms to the “real” side of the economy where progress has been limited at best.

However, developments in both equity and currency markets since November 2015 point to the 

challenges that persist in financial market liberalization. Equity markets remained volatile into 

2016, falling substantially in the first half of January 2016. The RMB continued to depreciate 

further relative to the dollar during this period. The spread between the CNY and CNH exchange 

rates widened again, with the RMB worth less offshore than on the onshore market. The PBC 

was reported to have intervened heavily in the offshore (CNH) market on January 12, forcing 

convergence of the two exchange rates and sharply driving up RMB borrowing costs in Hong 

Kong.97 News reports also indicated that the PBC was limiting dollar purchases by households 

and corporations in order to limit capital outflows and support the RMB.98 These measures, 

which are presumably temporary, do not necessarily mean that the PBC is rolling back the shifts 

towards capital account opening and a more flexible exchange rate. 

These actions also do not by themselves invalidate or bring into question the technical aspects on 

which the IMF based its determination of the RMB’s eligibility to be included in the SDR basket. 

However, such actions would certainly pose some technical difficulties for the RMB’s inclusion 

in the SDR basket if they were to persist for an extended period. Deviations between the onshore 

and offshore exchange rates would vitiate the notion of the onshore rate being a “market-based 

exchange rate” that could be used as a representative exchange rate for the RMB. As the IMF’s 

August 2015 report puts it, “Deviations between the two rates imply that the CNH cannot be a 

perfect hedge for CNY-based exposures.”99 The impact of this divergence on SDR users would 

be mitigated if they had access to both the onshore and offshore markets for conducting spot 

exchange rate transactions, which is not presently the case. 

The IMF’s positive decision should help strengthen the hands of economic reformers in China 

 96 The previous formula essentially involved summing up the country’s exports and the stock of global 

foreign exchange reserves held in assets denominated in its currency.

97 “Intervention as Offshore Shorts Get Squeezed,” Bloomberg News, January 12, 2016. 

98 “China Steps Up Capital Controls to Stem Outflows,” Financial Times, January 8, 2016.

99 “Review of the Method of the Valuation of the SDR—Initial Considerations” IMF, August 2015.
89

and enable them to sustain momentum on financial sector liberalization and reforms. However, 

progress even in this area is far from certain. Domestic opposition to further financial sector 

reforms and market-oriented liberalization measures remains fierce, and the IMF decision by 

itself is unlikely to shift the balance substantially.

The decision will therefore not be an immediate game-changer in terms of generating a surge of 

capital inflows into China. SDRs currently account for less than 3 percent of reserve asset 

holdings worldwide, so the direct effect of including the RMB in the SDR basket will not be 

large. Private financial institutions do not have any portfolios that are benchmarked against 

SDRs, so no portfolio rebalancing effect will follow. But the symbolic effect could be 

significant, as the RMB’s recognition as an official reserve currency is likely to encourage 

central banks around the world to begin adding RMB assets to their reserve portfolios. The 

IMF’s imprimatur will help, but ultimately it is the availability of sufficient high-quality RMBdenominated financial assets and the ease of moving financial capital into and out of China that 

will determine the RMB’s trajectory as a reserve currency.

There could be significant effects on the patterns of global capital flows if this decision does lead 

to further financial sector reforms, capital account liberalization, and exchange rate flexibility in 

China. These changes would open the doors for more capital inflows into China and also further 

tilt the composition of China’s outflows away from foreign exchange reserve accumulation by 

the central bank, as it will spur more foreign investments by China’s households, corporations, 

and institutional investors.

The IMF argued that its decision would be good for both China and the international monetary 

system, stating: 

Put into a broader context, the inclusion of the [RMB] in the SDR basket could be seen as 

an important milestone in the process of China’s global financial integration. It also 

recognizes and reinforces China’s continuing reform progress. As this integration 

continues and further deepens, and is paralleled in other emerging market economies, it 

could bring about a more robust international monetary and financial system, which in 

turn would support the growth and stability of the global economy. The RMB’s inclusion 

will also enhance the attractiveness of the SDR as an international reserve asset, as it 

diversifies the basket and makes its composition more representative of the world’s major 

currencies.100

 100 The IMF has posted a Q&A about its decision at: http://www.imf.org/external/np/exr/faq/sdrfaq.htm. 
90

8. Sequencing and Transitional Risks

It is important to understand how China has sequenced capital account liberalization relative to 

other policy changes and how that affects the benefit/risk trade-off from capital account opening. 

This sequencing has implications for China’s growth and financial stability, and therefore for the 

RMB’s international role. 

Is China putting the cart before the horse by pushing forward with capital account opening 

before fully freeing up its exchange rate? There is considerable evidence from other developing 

economies’ experiences that opening up the capital account without a flexible exchange rate is 

risky.101 A fixed or tightly managed nominal exchange rate makes it harder to cope with capital 

flow volatility because the exchange rate cannot act as a shock absorber.

An analysis of China’s international investment position that both traces its evolution over time 

and provides a cross-country perspective suggests that the economy faces only modest risks from 

a more open capital account in terms of vulnerability to external shocks. China’s gross capital 

inflows since 2000 have been mostly in the form of FDI. An examination of China’s latest 

international investment position confirms that FDI liabilities now account for 56 percent of 

China’s total (gross) external liabilities (see Table 2-1, Chapter 2). FDI and portfolio equity 

together account for 70 percent of external liabilities. FDI is considered the best type of capital 

inflow because it is stable and often brings with it transfers of technological and managerial 

expertise. Portfolio equity flows tend to be associated with the collateral benefit of developing 

and deepening domestic equity markets, but tend to be more volatile than FDI. Nevertheless, this 

structure of liabilities—dominated by FDI and portfolio equity—is consistent with the objective 

of sharing risk across countries, with foreign investors bearing capital as well as currency risk on 

such investments.

Another source of risk is that an open capital account often encourages an accumulation of 

external debt. Short-term foreign-currency-denominated external debt has been the scourge of 

emerging markets and was a major source of vulnerability for Latin American and Asian 

economies during the 1980s and 1990s. China has traditionally had a low level of external debt, 

which amounted to about $900 billion or 9 percent of GDP in 2014, much lower than that of any 

other major emerging market.102 China’s overall external balance sheet shows that its economy is 

quite well insulated from external shocks as net foreign assets amounted to nearly $1.4 trillion in 

the first quarter of 2015. In other words, China has enough foreign assets to not only meet all its 

external debt obligations but also to more than cover all of its foreign liabilities. In short, China 

is not subject to the traditional risks associated with opening up the capital account in advance of 

increasing exchange rate flexibility.

 101 For a discussion of the issue of sequencing capital account liberalization in the context of China, see 

Prasad, Rumbaugh, and Wang (2005) and references therein. Goodfriend and Prasad (2007) discuss the 

implications of China’s exchange rate regime for monetary policy formulation and implementation. For a 

description of the challenges facing China’s financial system, see Lardy (2011) and Prasad and Ye 

(2012).

102 IMF, 2015.
91

The bigger risks may be domestic. The combination of a tightly managed exchange rate and an 

increasingly open capital account undermines the ability of the central bank to use monetary 

policy instruments such as interest rates to maintain domestic price stability. Although its capital 

account is not fully open, this constraint applies to China as well because the capital account is in 

fact rather porous and becomes even more so when interest differentials with the rest of the 

world increase and the incentives to evade controls strengthen.

103 If the United States has low 

rates while China ought to have higher interest rates to manage inflation, the Chinese central 

bank is constrained in raising rates as that may attract more inflows. Indeed, the expectations of 

RMB appreciation in previous years that resulted from the tight management of the RMB’s value 

may have fueled more speculative inflows. The reverse is true as well. As discussed in greater 

detail below, capital outflows at a time of domestic economic weakness can also complicate 

domestic policymaking.

Moreover, lifting restrictions on capital flows could also be risky for the financial system. 

Further freeing-up of outflows while maintaining a cap on deposit interest rates could cause 

households and corporations to shift deposits out of the banking system. Banking sector earnings 

had traditionally depended heavily on net interest margins that are mandated by the government 

through the deposit rate ceiling, which has now been dismantled, and, until July 2013, the 

lending rate floor. Substantial deposit withdrawals for other reasons, including concerns about 

the stability of the banking system, can themselves damage banks and strain the entire domestic 

financial system.

How worried should China be about these risks? The government’s control of its financial 

markets, combined with the resources needed to back up its banks, should prevent these risks 

from escalating into a full-blown banking or broader financial crisis. Nevertheless, it could 

require extensive government resources to keep the system stable in difficult times. Even 

discounting the possibility of a systemic crisis in the Chinese financial system, there are many 

fragilities in the banking system and in the unregulated parts of the financial system that are 

cause for serious concern. A capital account that is becoming increasingly open could exacerbate 

these tensions. So how is China managing the difficult act of getting the sequence of its reforms 

right?

The literature on financial openness indicates that its potential benefits—in terms of both risksharing and growth—become apparent only after a country has attained a high level of financial 

integration. For a country that is in the process of opening up its capital account, there are 

significant transitional risks if it falls below certain threshold conditions, especially those related 

to domestic financial and institutional development. A difficult paradox results from the fact that 

financial opening itself serves as a catalyst for financial market development and improvements 

in institutions, especially corporate governance. There is no general recipe for how to strike the 

right balance between these collateral benefits and the risks of premature capital account 

liberalization.

104 The academic literature on this topic suggests that the transitional risks cannot 

be eliminated, but they can be mitigated through supporting conditions such as greater exchange 

 103 See Goodfriend and Prasad (2007).

104 See Kose, Prasad, Rogoff, and Wei (2009). 
92

rate flexibility and a more selective approach to capital account liberalization that is designed to 

attain certain specific collateral benefits.105

8.1. Controlled Liberalization to Manage Risks during Transition

Some commentators (including the author of this report) have in the past argued that a piecemeal 

approach to reforms may not be tenable for China when it comes to issues such as exchange rate 

flexibility and capital account liberalization.106 The logic seems straightforward—making the 

currency more flexible gradually could lead to a wave of capital flooding into (or out of) the 

economy, depending on economic conditions and notwithstanding capital controls, as there 

would be a tempting opportunity for a one-way bet on the currency’s appreciation (or 

depreciation). Some researchers have also argued that there are good reasons for China to move 

ahead with exchange rate flexibility before opening up the capital account.107

In practice, the Chinese government has in fact managed to sustain a gradual approach to making 

the exchange rate regime more flexible. It has been somewhat more aggressive in its approach to 

capital account opening. For instance, as discussed in Chapter 2, the Chinese government 

liberalized outflows in 2010 in a calibrated manner through an expansion of the QDII scheme. 

The QDII approach gives the government much greater control over when and how much money 

could be taken offshore, as the QDIIs are given specific investment quotas each year. Such 

approaches allowing for private capital outflows in a controlled approach is better in many ways 

than the inefficient approach of having the government recycle foreign currency inflows through 

official channels in the form of reserve accumulation. The QDII scheme reduces the need for 

foreign exchange market intervention, gives private investors a chance to diversify their 

portfolios by increasing foreign investments, and also encourages Chinese banks to be more 

efficient by increasing competition in the financial system.

Similarly, the QFII and RQFII schemes that create more channels for inflows, along with the free 

trade zones and mutual fund connect and stock connect programs that allow for flows in both 

directions, are all part of the controlled approach to capital account liberalization. These 

programs allow the government to control the volume of flows in both directions and, to a 

significant extent, the composition of flows as well.

8.2 Capital Outflows

Even as the Chinese economy continued to post relatively robust growth rates in the aftermath of 

the financial crisis and became the main driver of world growth, political uncertainty related to 

the leadership transition during the summer and fall of 2012 led to concerns about capital flight

from China.

 105 See Prasad and Rajan (2008).

106 See, for instance, Prasad and Rajan (2008). 

107 See Prasad, Rumbaugh, and Wang (2005), and Prasad and Rajan (2005, 2006, 2008).
93

What was true even in 2012 was that weaker inflows and stronger outflows (including an 

increase in foreign currency deposits as exporters held more of their earnings abroad in foreign 

currencies) led to a more evenly balanced position of capital outflows and inflows. These swings 

seemed to be quite similar to those experienced by many other emerging markets.

In the first half of 2012, with the euro zone debt crisis worsening, investors worldwide appeared 

to be more concerned about safety than high returns. Consequently, there was a flow of capital 

out of emerging markets around the world to safe havens, especially to the United States but also

to Japan and Switzerland. In August 2012, the European Central Bank announced its Outright 

Monetary Transactions (OMT) backstop for sovereign debt of the euro zone periphery 

economies. That eased immediate concerns about global spillovers from euro zone problems and 

capital started flowing back to emerging markets, including China.

These changes in the patterns and timing of flows illustrate one important point—that China is 

looking like many other emerging markets in terms of what factors lead to capital flowing in or 

out. Some of the increase in capital outflows from China is certainly consistent with the 

government’s steps to liberalize outflows. Non-government outflows are likely to increase 

further as Chinese corporations look for investment opportunities abroad and as financial market 

development allows households to take advantage of avenues for diversifying their savings into

foreign investments.108

However, the scale of recent outflows indicates how quickly sentiments about economic and 

financial market conditions can shift. These capital flow surges in one direction or another can be 

exacerbated if the exchange rate is not allowed to adjust freely, and speculative pressures on the 

currency start building up.

The downward pressures on the RMB–dollar exchange rate after the PBC announced a shift to a 

more market-determined exchange rate on August 11, 2015 exemplify this phenomenon. In the 

immediate aftermath of this shift, which was accompanied by a nearly 2 percent devaluation of 

the RMB relative to the dollar (as noted earlier), financial market participants appeared to 

interpret the move as signaling Chinese policymakers’ concerns about the state of the economy. 

This move, in tandem with the sharp fall in mainland stock markets since July 2015, appears to 

have increased outflows. Foreign exchange market intervention to keep the RMB’s value from 

falling sharply in the second half of August led to a reduction in foreign exchange reserves. 

SAFE data indicate that the reserve losses may have been about $94 billion, although it is not 

clear if any of this represents currency valuation effects on the value of China’s massive foreign 

exchange reserve portfolio or actual foreign exchange market intervention.

China has taken major steps down the path of capital account liberalization that will be difficult 

to reverse. In the absence of other domestic reforms, especially the financial sector development 

and liberalization that are necessary to support a more open capital account, the result could be 

more volatility with few of the benefits of financial openness.

 108 For a discussion of China’s outward investment strategy, see Rosen and Hanemann (2009) and 

Scissors (2011).
94

8.3 Capital Flight

A more worrisome aspect of capital outflows is related to capital flight, which could occur 

through both illegitimate and legitimate channels. One possibility, which is difficult to verify for 

obvious reasons, is that the government’s crackdown on corruption is leading to some capital 

leaving the country for fear of expropriation as part of the crackdown process. On the other hand, 

these flows could also represent outward investments reflecting the same concerns about 

macroeconomic and financial stability laid out earlier. These factors are difficult to disentangle 

but the correlation between these two types of flows, which may rise when an economic 

slowdown and factors such as the corruption crackdown coincide, raises concerns about surges 

of capital outflows that in turn could threaten financial stability.

Casino operations in Macau have long been seen as a major conduit for money laundering and 

illicit capital flows. A variety of techniques are used to launder money through casinos and carry 

out cross-border monetary transfers for individual customers, sometimes without any actual 

transfer of funds involved.109 A paper analyzing this phenomenon concludes,

There is no doubt that this channel can also serve for the movement of funds of an illicit 

origin, whether coming from corruption, embezzlement of public or private entities, or 

any other sources. Hence the particular need for rules and procedures for the detection of 

illegal transfers.110

Regulatory authorities on the mainland have long been cognizant of this conduit and have 

recently taken aggressive steps to combat these operations as capital flight has picked up. On 

August 21, 2015, the PBC and the Monetary Authority of Macao signed the Memorandum of 

Understanding on Prevention of Money Laundering and Terrorist Financing. In an official 

notice, the PBC said the agreement would strengthen bilateral exchanges, including those on 

anti-money laundering regulations, information exchange mechanisms, and on-site 

inspections.111

 109 This text from Gordinho (2013) summarizes the types of transactions involved: “Briefly, money 

laundering through casinos generally has two types of objectives. The main objective is to pass the funds 

through the casino, typically taking as an entry point the buying of gambling chips, followed by the 

placing of bets, usually of reduced values or bets that in most cases cancel each other out (black and red 

on roulette, both teams in sports betting, etc.) in order to avoid significant amounts of losses. The gaming 

session ends with the redemption of the chips through the issuance of a casino check. A secondary 

objective may be to ensure that these transactions (buying chips, placing of bets, redeeming chips) are 

split or divided so that each does not exceed the value that triggers the automatic recording of operations, 

a practice known in the jargon as ‘smurfing’. . . . Gaming promoters may assist in the transfer of funds to 

the casinos of Macau. In the case of VIP Baccarat, the amounts involved can be very significant. 

Moreover, in many cases, there will be no actual transfer of funds, but rather a simple balancing of 

accounts between credits in mainland China and debits in Macau. This is one of the reasons why the 

gaming promoter sector [in Macau] is rather developed.”

110 See Gordinho (2013).

111 “Monetary Authority of Macao and People’s Bank of China entered into MOU on Prevention of 

Money Laundering and Terrorist Financing,” PBC Press Release, August 21, 2015. 

http://bit.ly/1YDAKwP; and “Mainland, Macao ink pact to fight money laundering” The State Council, 

August 22, 2015. http://bit.ly/1Tgjom9.
95

An alternative channel that has been identified by SAFE is also difficult to measure but is

regarded as widely prevalent. This channel is related to informal financial institutions that act as

conduits for cross-border transfers. The system works as follows: At agreed-to exchange rates,

underground banks transfer foreign currency funds to the offshore banking accounts of wealthy

individuals while receiving local currency funds using anonymous domestic accounts, with no

actual capital moving across the border. The accounting is balanced through shell companies,

false invoices, and other instruments. According to SAFE,

the PBoC [the PBC], the Ministry of Public Security, the Supreme People’s Court, the

Supreme People’s Procuratorate and the SAFE took a nationwide special action against

transfer of illegal income through offshore companies and underground banks in mid-tolate April, and have solved some major underground bank cases, thus strongly

intimidating lawbreakers.112

China’s Ministry of Public Security is reported to have recently cracked down an illegal foreignexchange network that it said handled up to $64 billion in transactions. In early September,

authorities discovered 37 underground banking dens accounting for deals totaling more than $38

billion, according to a statement on the ministry’s website.113

Trade misinvoicing is another well-recognized way to circumvent capital controls. 

Overinvoicing imports or underinvoicing exports is a method of transferring funds out of a 

country. During the mid-2000s, when there was considerable incentive to bet on RMB 

appreciation, China faced the opposite problem of imports being underinvoiced and exports 

being overinvoiced. This problem provided a conduit for capital inflows. Such misinvoicing is 

even easier in the case of services trade, where it is harder to match financial flows with actual 

trade transactions since there are no tangible goods involved.114

By definition, illicit capital flows are difficult to measure. One widely used measure based on 

official data is the net errors and omissions (NEOs), which is the residual in the balance of 

payments accounting and reflects unrecorded capital account or current account transactions. 

Negative NEOs typically reflect money leaving the country through unofficial channels. For 

China, NEOs have been persistently negative since 2009 (Figure 8-1). During 2014, such 

outflows amounted to $140 billion and in the first half of 2015 alone they amounted to $90

billion.

 112 Press Conference on SAFE’s Policies for 2015 Q3, http://bit.ly/1MRsvFV. 113 Press Conference on SAFE’s Policies for 2015 Q3 http://bit.ly/1MRsvFV; “China police reveal busted

illegal banking operation,” Wall Street Journal, November 20, 2015; and “China arrests 75 in crackdown

on underground banks,” Reuters, September 30, 2015.

114 See, for instance, Andreas Buehn and Stefan Eichler, 2011, “Trade Misinvoicing: The Dark Side of 

World Trade,” World Economy, Vol. 34:8, pp. 1263-1287.
96

Figure 8-1. China: Net Errors and Omissions

(in billions of U.S. dollars)

Source: SAFE via CEIC

A number of other motives for capital flows from China to the United States, through both 

legitimate and illegitimate channels, exist. One is related to real estate purchases, which may also 

have been boosted by safe haven inflows into the United States during the anti-corruption drive 

in China. These purchases could also reflect the desire on the part of Chinese investors to 

diversify their portfolios into hard assets at a time of low worldwide yields from fixed-income 

assets and volatile returns on equities. The U.S. National Association of Realtors reports that 

sales of residential real estate to Chinese clients (including those from Hong Kong and Taiwan) 

now exceed sales to clients from any other country. For the 12-month period ending in March 

2015, the estimated value of sales to Chinese clients was about $28 billion, more than double the 

level of $13 billion in 2013, and more than double the sales to clients from any other country.115

Flows into other housing markets, such as those in Hong Kong, have also been large and volatile 

in recent years.116

Another factor that could be boosting inflows into the United States is related to the large 

number of tuition-paying Chinese students enrolled in U.S. institutions of higher education. The 

Institute of International Education estimates that about 305,000 Chinese students were enrolled 

in U.S. universities in 2014-15, representing 31 percent of the total foreign student enrollments 

 115 “Chinese Pull Back from U.S. Property Investments,” Wall Street Journal, November 27, 2015.

116 For an analysis of the effects of official and illegitimate capital flows from mainland China on equity 

and property market prices in Hong Kong, see Yin-Wong Cheung, Kenneth K. Chow and Matthew S. 

Yiu, 2015, “The Nexus of Official and Illicit Capital Flows ‐ The Case of Hong Kong,” HKIMR 

Working Paper No. 25/2015. 

-160	

-120	

-80	

-40	

0	

40	

2000	 2001	 2002	 2003	 2004	 2005	 2006	 2007	 2008	 2009	 2010	 2011	 2012	 2013	 2014	 2015	

H1	
97

in U.S. universities.117 China’s government does not bar the transfer of funds abroad for 

educational purposes, which could be fueling financial flows to other countries such as the 

United Kingdom as well.

A third category is related to procurement of visas that are (or, in the case of Canada, were) 

offered to investors who can bring in large sums of money and create jobs. In the United States, 

EB-5 immigrant visas provide a path for obtaining permanent residency (green cards) for 

foreigners who invest a minimum of $500,000 and create at least 10 jobs in the country. The 

program, which caps the annual number of visas issued at 10,000, hit that limit for the first time 

in August 2014. Chinese nationals accounted for nearly 90 percent of EB-5 visas issued during 

2014, compared with just 13 percent in 2004. That translated to 8,308 EB-5 visas for Chinese 

nationals last year, a huge surge from a decade ago, when only 16 visas were granted to 

Chinese.118

Although it may be premature to declare a capital flight crisis, particularly given China’s 

relatively strong external balance sheet with a relatively low level of external debt and a large 

stock of foreign exchange reserves, the government is certainly concerned about illegitimate 

outflows and the fact that they may exacerbate overall capital outflows and add to 

macroeconomic stresses the economy is already facing. This may be one reason the government 

is reluctant to let the RMB depreciate significantly against the dollar.

The key challenge the government faces is to stabilize market expectations about the future path 

of the currency. The PBC’s response has been to try and generate two-way volatility in the 

RMB-dollar exchange rate in order to forestall speculative activity. The PBC has done this 

through aggressive intervention in both the onshore and offshore foreign exchange markets. This 

could prove to be an expensive and unviable strategy, especially since it is in conflict with the 

objective of allowing for a more market-determined exchange rate. An approach that is likely to 

have more success is to let the currency float more freely and directly address concerns about the 

trajectory of the economy using a balanced mix of macroeconomic policies and market-oriented 

reforms to the real side of the economy. In the absence of such reforms, and if the economy 

continues to lose growth momentum, capital flow and currency dynamics could become even 

more difficult to manage, adding to the risks of short-term financial and macroeconomic 

instability.

 117 See, Institute of International Education, “Top 25 Places of Origin of International Students,” 

http://www.iie.org/Research-and-Publications/Open-Doors/Data/International-Students/Leading-Placesof-Origin/2013-15

118 These figures are based on government data compiled by CNNMoney. See “U.S. runs out of investors 

again as Chinese flood program,” CNNMoney, April 15, 2015.
98

9. The RMB’s Impact on the World

This chapter analyzes the potential impact of the RMB’s rise on the competitive balance of 

global reserve currencies, and discusses the effects that the internationalization of the RMB

could have on the structure of global capital flows. 

9.1. Effects on the Asian and International Monetary Systems

Promoting the RMB’s international role is tied up with many complex domestic and geopolitical 

considerations. As with all of its policies, China is working towards multiple objectives. For 

now, China will continue promoting the international use of the RMB using Hong Kong as a 

platform. When the Chinese government determines that its financial markets are finally strong 

enough to allow for a more open capital account, it is likely that promotion of Shanghai as an 

international financial center could take precedence, especially as that would fit better with its

domestic financial market development objective.

While using Hong Kong as the main staging ground for the internationalization of the RMB, the 

Chinese government is also working to promote competition among financial centers eager to 

engage in RMB business. Regional and international financial centers such as Bangkok, 

Frankfurt, London, and Singapore are all being given opportunities to engage in RMB

transactions. This competition enables Beijing to continue its program of internationalizing the 

RMB without having to fully open its capital account.

Why are so many countries eager to sign currency swap lines with China and even hold its 

currency as part of their reserve portfolios? This may be less a sign of the RMB’s inevitable 

march to global dominance than it is a low-cost bet on a likely outcome of a convertible and 

more widely accepted global currency. Equally important is the desire on the part of many 

economies to maintain a good economic relationship with China in anticipation of its rising 

economic power. Holding RMB reserves may in effect be a simple way of trying to buy 

protection from China, which in turn may be better motivated to provide help to a central bank 

that has assisted the RMB in its early stages of ascendance. The amounts are small but still the 

symbolism is hard to miss. Central banks around the world are preparing for a future in which 

the RMB will start playing an increasingly prominent role in international finance and may 

ultimately become a reserve currency. A more open capital account will allow the RMB to play 

an increasingly significant role in Asian as well as global trade and finance, but in a manner that 

allows the Chinese government to retain some control over capital flows.

9.2. Will the RMB’s Rise Add Stability to Regional and Global Finance?

There is no clear guidance from economic theory about how many currencies would be best for a 

world economy that is becoming increasingly closely integrated. Having a system with multiple 

reserve currencies but with just one principal reserve currency has fueled a number of 

complications such as persistent global current account imbalances, suggesting that it may not be 
99

the optimal situation from the perspective of promoting the stability of the global financial 

system.119

If multiple reserve currencies are indeed desirable, how should one assess the prospects of other 

currencies that could compete with the dollar? The history of the rise and fall of reserve 

currencies does offer some useful lessons. The key is for a country to have sound economic 

policies, well-developed financial markets, and public institutions that are trusted by domestic 

and foreign investors. These are the relevant criteria that put a country’s currency in a position to 

develop into a reserve currency.

The argument for a world with multiple reserve currencies in a stable competitive equilibrium 

might be obvious if the world economy was starting with a clean slate. But the argument is far 

from clear cut given the present state of financial markets and the level of international financial 

integration. Events during the financial crisis present a counter-argument to the notion that 

having more reserve currencies is better.

The dollar’s dominance has allowed the Fed to act as a credible global lender of last resort, a role 

that few other central banks are capable of playing. However, there is a risk of confusing cause 

and effect here. One reason the world was in search of dollar liquidity during the crisis is that 

many global banks had sought large amounts of cheap dollar funding to finance their worldwide 

operations. U.S. monetary conditions, which led to an aggressive search for yield through 

financial innovations, and the fertile ground provided by U.S. financial markets for such 

sophistry, were important elements in making many global banks depend so heavily on dollar 

liquidity.

While the RMB is likely to become a significant reserve currency over the next decade, it is 

unlikely to challenge the dollar’s dominance. There is still a huge gulf between China and the 

United States in the availability of safe and liquid assets such as government bonds. The depth, 

breadth, and liquidity of U.S. financial markets will serve as a potent buffer against threats to the 

dollar’s preeminent status. Rather than catching up to the United States by building up debt, the 

challenge for China is to develop its other financial markets and increase the availability of highquality RMB-denominated assets.

9.3. Implications of a Rising RMB for China–U.S. Financial Flows

China does not report the currency composition of its foreign exchange reserve holdings, but it is 

widely believed that about two-thirds are in U.S.-dollar-denominated instruments. Data drawn 

from the U.S. Treasury International Capital System (TIC) provide at best a partial picture 

because they track the country of the purchasing agents rather than the actual owners of U.S. 

securities. Based on the TIC data, the total value of China’s reported holdings of Treasuries and 

agency bonds as of July 2015 was $1.24 trillion. This total amounts to about 21 percent of the $6 

trillion worth of Treasury securities held by all foreign investors, including foreign central banks

(Figure 9-1). This share is down from 28 percent in 2011.

 119 The discussion in this section draws on Prasad (2014). 
100

The TIC data suggest that the absolute amount of Treasury securities held by China has remained 

relatively stable over the past three years, even though China’s foreign exchange reserves have 

fallen by nearly $500 billion since June 2014. Thus, it does not appear that China has been 

selling U.S. Treasury securities while trying to prevent RMB depreciation. China’s declining 

share of U.S. government debt ownership indicates that other investors, both domestic and 

foreign, are maintaining their strong demand for U.S. Treasuries. Moreover, given the U.S. 

federal government’s substantially lower financing needs at present, especially relative to the 

period during and in the immediate aftermath of the financial crisis, it is unlikely that reduced 

purchases of Treasury securities by China will have a substantial effect by itself on the U.S. 

Treasury yield curve.

Figure 9-1. China’s Holdings of U.S. Treasury Securities

(in billions of U.S. dollars)

Source: U.S. Treasury International Capital System

Note: This chart shows Treasury holdings by China as of end-June each year.

An analysis of China’s investment position in the United States shows that Treasury and agency 

debt (issued by U.S. government-sponsored enterprises) continues to dominate in the total stock

position (Figure 9-2). Chinese portfolio investment in the United States has expanded rapidly, 

from $29 billion in 2007 to $320 billion in 2014. Direct investment from China to the United 

States has been growing rapidly but, in absolute amounts, still stands at a relatively modest $9.5 

billion in 2014.

0.0 

7.5 

15.0 

22.5 

30.0 

0 

350 

700 

1,050 

1,400 

2001 2003 2005 2007 2009 2011 2013 2015 

Holdings by China 

Percentage Share of the Total 

Foreign Holdings (right scale) 
101

Figure 9-2. Breakdown of China’s Investment Position in the United States

(in billions of U.S. dollars)

Sources: Bureau of Economic Analysis and U.S. Treasury International Capital System

Notes: This chart shows the position of China’s direct investment and other types of securities holdings in 

the U.S. Except for direct investment, all other categories are based on data at end-June each year. Data 

on China’s direct investment position are unavailable before 2003.

China’s capital account liberalization could have significant effects on the volume and, more 

importantly, the composition of investments in the United States. The major channel for capital 

flows to the United States has been the official accumulation of foreign exchange reserves, as 

suggested by the numbers above. A more flexible exchange rate and a broader financial system 

that facilitates hedging against currency risk would reduce reserve accumulation while 

simultaneously reducing the “fear of floating” (i.e., concerns about currency volatility). A deeper 

and broader financial system would also reduce the risks from the greater capital flow volatility 

to which China will be exposed as the capital account becomes more open. For instance, a richer 

set of derivatives markets would enable private agents, including corporations, to insure against a 

variety of risks associated with capital flows, mitigating the need for reserves as a public 

insurance mechanism.

Shifting away from policies that intensify reserve accumulation would also allow China to 

change the structure of its foreign investments. In particular, capital outflows would reduce the 

pressure on the currency. In the absence of well-developed financial markets that facilitate 

foreign investments by households, this function of investing abroad is to some extent being 

carried out by other government agencies. China’s sovereign wealth fund, the China Investment 

Corporation (CIC), and other large institutional investors are already moving aggressively into 

investments that offer higher yields than U.S. Treasuries or government bonds of other reserve 

currency economies. CIC is shifting away from government bonds into higher-yielding assets. 

0 

3 

5 

8 

10 

0 

350 

700 

1050 

1400 

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 

Treasury Debt 

Agency Debt 

Equity 

Corporate Debt 

Direct Investment (right scale) 
102

The share of equity holdings in its portfolio rose from 36 percent in 2009 to 48 percent in 2010. 

Among its diversified fixed-income securities, roughly a third were invested in corporate bonds 

in 2010, compared with 13 percent in 2009.

120

As Chinese financial markets continue to develop and private investors increase the international 

diversification of their portfolios, these shifts in China’s outward investment patterns are likely 

to become more pronounced. At present, China invests a relatively small amount in U.S. 

equities. This is likely to shift as capital account openness leads to more capital flowing out of 

China in search of diversification and yield. This could result in rising flows into various asset 

markets in the United States, from equities to real estate.

Thus, the various policy reforms that are needed to support the international role of the RMB 

could also create significant changes in China’s economy and the patterns of its capital inflows 

and outflows, both overall and also specifically from and to the United States.

9.4. Effects of the RMB’s Rise on the U.S. Dollar

It is likely that, as the RMB becomes a prominent international currency, and as the costs of 

transacting in the RMB and other emerging market currencies falls, the dollar’s prominence as a 

unit of account (for denominating trade transactions) and as a medium of exchange (for 

settlement of cross-border financial trade and financial transactions) will decline. This could 

affect the use of the dollar in international financial markets, which by itself will not necessarily 

have a substantial impact on the U.S. economy. However, these developments, in tandem with 

measures taken by China to develop its own payment system, could diminish the primacy of U.S. 

financial institutions. This would affect the ability of the United States to continue wielding the 

financial clout that it currently has as a result of the dollar’s dominance in international finance.

It has also been argued by some that the RMB is on a trajectory to displace the dollar as the 

dominant global reserve currency.121 However, China is missing one crucial ingredient: the 

world’s trust. To achieve currency dominance, China needs more than economic and military 

might; it requires a broader and more credible set of public and political institutions.

122 Indeed, 

the importance of such institutions was apparent in the aftermath of the global financial crisis. 

Even though America’s financial markets nearly collapsed, its public debt levels rose sharply, 

and the Federal Reserve was forced to undertake massive monetary expansion to support the 

economy, the dollar strengthened relative to most other currencies.

This strengthening occurred because global investors seeking a safe haven still automatically 

turn to U.S. Treasury securities in times of global financial turmoil. Foreign investors now hold 

nearly $6.5 trillion of these low-yielding securities, not to mention large quantities of other dollar 

assets. And the dollar’s share in global foreign-exchange reserves has held steady since the crisis.

Indeed, recent data from the IMF suggest that the dollar’s share of global foreign exchange 

reserves has increased slightly, to about 64 percent, in the last two years (Figure 9-3).

 120 See Prasad and Ye (2012). 

121 See Chen, Peng, and Shu (2009), Subramanian (2011), and references therein. 

122 For a detailed version of this argument, see Prasad (2014).
103

Figure 9-3. Currency Composition of Global Foreign Exchange Reserves

(in percent of allocated reserves)

Source: IMF 

This outcome can be explained partly by the fact that the United States boasts the world’s 

deepest and most liquid financial markets. But the most important factor supporting America’s 

currency dominance is the institutionalized system of checks and balances that operates between 

the executive, legislative, and judicial branches of its government. Trust in U.S. public 

institutions is rooted in the open and transparent democratic process that underpins them. The 

U.S. legal system—independently of the executive and legislative branches of government—

further supports the dollar’s global role.123

This institutional framework contrasts sharply with China’s single-party system, in which the 

level of government accountability is much lower. The reality is that, despite China’s economic 

heft and low central-government public debt, foreign investors are unlikely to trust China with 

large sums of money. Capital inflows—which will undoubtedly increase in the coming years—

are driven largely by investors’ interest in diversification and high yields, rather than the 

country’s image as a refuge from troubled financial markets elsewhere, especially given that 

China’s financial markets are relatively underdeveloped and beset by considerable risks.

Depending on how soon China opens up its capital account and develops its financial markets, 

the RMB could become a significant reserve currency in the near future. But it will not contest 

the dollar’s supremacy unless China’s leaders align the country’s political and legal institutions 

with its economic reforms. It appears unlikely that the Chinese government is willing to 

 123 See Prasad (2014). 

0 

10 

20 

30 

40 

50 

60 

70 

80 

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 

dollar 

euro 

yen 

sterling 

other 
104

undertake the broad reforms needed to underpin the RMB’s status as a safe haven currency, 

rather than just a reserve currency. A more likely scenario is that, conditional on continued 

reforms, the RMB’s share of global foreign exchange reserves could rise to a level of about 10 

percent over the next decade, with most of this increase coming from corresponding declines in 

the shares of existing reserve currencies such as the euro, the Japanese yen, and the pound 

sterling. The RMB may slightly erode but is unlikely to seriously challenge the dollar’s 

dominance as the main global reserve currency.

9.5. Summary

China’s rapidly growing size and dynamism are enormous advantages that will help promote the 

international use of its currency, especially within Asia. However, its low level of financial 

market development is a major constraint on the pace at which the RMB attains reserve currency 

status. Moreover, in the absence of an open capital account and free convertibility of the 

currency, it is unlikely that the RMB will become a prominent reserve currency, let alone 

challenge the dollar’s status as the leading one.

China is also likely to continue deploying its resources through other channels that enable it to 

pursue its economic objectives and simultaneously promote its geopolitical interests. China has 

set up the Asian Infrastructure Investment Bank, created a $40 billion Silk Road Fund aimed at 

promoting outward investment and trade, and has been a key contributor to two joint initiatives 

with other BRICS economies—the New Development Bank and the Contingent Reserve 

Arrangement, a reserve pooling fund. Such alternatives will allow China to diversify its foreign 

investment allocations beyond traditional investments, yielding better economic returns and also 

an intangible but substantial payoff in terms of increased influence in Asia and beyond. These 

channels will also help promote the international use of the RMB.

The RMB’s rising prominence as a reserve currency could in principle add to the stability of 

regional and international financial systems. This in turn requires that China’s macroeconomic 

policies and financial market development and regulation be conducive to China’s own 

macroeconomic and financial stability. This favorable outcome will also depend on whether 

China’s domestic financial markets and institutional development allow the RMB to become a 

credible safe haven currency. The RMB’s inclusion in the SDR basket could be seen as a way for 

the IMF—and the international community that it represents—to exercise leverage over China in 

internalizing the global repercussions of its domestic policies.
105

10. Conclusion

Given its size and economic clout, China is adopting a unique approach to the RMB’s role in the 

global monetary system. As with virtually all other major reforms, China is striking out on its 

own path to a more open capital account. This move is likely to involve removing explicit 

controls even while attempting to exercise “soft” control over inflows and outflows through 

administrative and other measures. On its present trajectory, China will have a nearly open 

capital account in the next two to three years, allowing the RMB to play an increasingly 

significant role in global trade and finance.

The selective and calibrated approach to capital account liberalization has been effective at 

promoting the RMB’s international presence without risking the potential deleterious effects to 

China of complete capital account liberalization. Indeed, the RMB is beginning to play a 

significant role in international trade transactions. It is making inroads into the global financial 

system and starting to appear in the reserve portfolios of a number of central banks around the 

world. It has also become a constituent of the basket of currencies that comprise the IMF’s 

Special Drawing Rights. These shifts, some of which are more symbolic than substantive at 

present, will develop critical mass over time and have the potential to start transforming the 

global monetary system. However, the full potential of the RMB’s international use cannot be 

realized without more active onshore development. It will be difficult, for instance, to fully 

develop China’s foreign exchange and derivatives markets in the absence of a more open capital 

account.

The RMB’s prospects as a global currency will ultimately be shaped by broader domestic 

policies, especially those related to financial market development, exchange rate flexibility, and 

capital account liberalization. As Chinese financial markets become more fully developed and 

private investors increase the international diversification of their portfolios, these shifts in 

China’s outward investment patterns are likely to become more pronounced. Thus, the various 

policy reforms that are needed to support the international role of the RMB could also create 

significant changes in China’s economy and the patterns of its capital inflows and outflows.

The RMB is already well on its way to becoming a widely used currency in international trade 

and finance. So long as China continues to make progress on financial sector and other marketoriented reforms, it is likely that the RMB will become an important reserve currency within the 

next decade, perhaps eroding but not displacing the dollar’s dominance.
106

Appendix A: Capital Account Categories in the AREAER

This section lists the categories used in the IMF’s AREAER, broken down by inflows (15

categories) and outflows (16 categories).

Inflows

1. Money Market (Bonds with Maturity of 1 year or less)

1.1. Purchase Locally By Non-Residents 

1.2. Sale or Issue Abroad By Residents 

2. Bonds (Bonds with maturity of greater than 1 year)

2.1. Purchase Locally By Non-Residents 

2.2. Sale or Issue Abroad By Residents 

3. Equities

3.1. Purchase Locally By Non-Residents 

3.2. Sale or Issue Abroad By Residents 

4. Collective Investments

4.1. Purchase Locally By Non-Residents 

4.2. Sale or Issue Abroad By Residents 

5. Derivatives Categories

5.1. Purchase Locally By Non-Residents 

5.2. Sale or Issue Abroad By Residents 

6. Guarantees, Sureties & Financial Backup Facilities 

7. Financial Credits 

8. Commercial Credits*

9. Real Estate Categories 

9.1.Purchase Locally By Non-Residents

10.Direct Investment 

Outflows

1. Money Market (Bonds with Maturity of 1 year or less)

1.1. Purchase Abroad By Residents 

1.2. Sale or Issue Locally By Non-Residents 

2. Bonds (Bonds with Maturity of greater than 1 year)

2.1. Purchase Abroad By Residents 

2.2. Sale or Issue Locally By Non-Residents 

3. Equities

3.1. Purchase Abroad By Residents 

3.2. Sale or Issue Locally By Non-Residents 

4. Collective Investments

4.1. Purchase Abroad By Residents 

4.2. Sale or Issue Locally By Non-Residents 

5. Derivatives Categories

5.1.Purchase Abroad By Residents 
107

5.2. Sale or Issue Locally By Non-Residents 

6. Guarantees, Sureties & Financial Backup Facilities

7. Financial Credits 

8. Commercial Credits* 

9. Real Estate Categories 

9.1.Purchase Abroad By Residents

9.2.Sale or Issue Locally By Non-Residents 

10.Direct Investment

Notes: The categories marked with an asterisk are the only ones for which the IMF has

determined that China does not impose any restrictions according to AREAER 2014. The list

above excludes one additional item listed under a separate category (Other) and described as

liquidation of direct investment. More detailed discussion on the categories can be found in

Fernández, A, M. W. Klein, A. Rebucci, M. Schindler, and M. Uribe (2015) “Capital Controls

Measures: A New Dataset,” NBER Working Paper No. 20970.
108

Appendix B: Selected Developments Pertaining to Capital Account

Policies and RMB Internationalization, 2004–2015

This appendix extends the documentation of changes to capital controls in Prasad and Wei 

(2007) and Prasad and Ye (2012) to September 2015, and also documents the developments 

related to the greater international use of the RMB and other relevant financial market 

developments. This is a selective list of key changes and is not intended to be comprehensive. A 

variety of official and unofficial sources were used in compiling this appendix. “AREAER” refers 

to the IMF’s Annual Reports on Exchange Arrangements and Exchange Restrictions; “HKMA” 

is the Hong Kong Monetary Authority; “PBC” stands for the People’s Bank of China; “CSRC” 

stands for China Securities Regulatory Commission; and “SAFE” stands for the State 

Administration of Foreign Exchange. All items from AREAER are quotations from the original 

source. 

Changes during 2004

January 1. Under the Closer Economic Partnership Arrangement, (1) the asset requirement for 

Hong Kong Special Administrative Region (SAR)–incorporated banks to open branches in 

mainland China was reduced to $6 billion from $20 billion; (2) the requirement that a 

representative office be set up in mainland China before a Hong Kong SAR bank established a 

joint venture bank or joint venture finance company in mainland China was lifted; and (3) the 

minimum number of years of business operations on the mainland required before mainland 

China branches of Hong Kong banks can apply for RMB business was reduced to two years from 

three years. (HKMA)

January 18. Mainland residents are allowed to use RMB-denominated bank cards for tourismrelated payments in the Hong Kong SAR. (AREAER 2004, 229, “Arrangement for payments and 

receipts” change)

February 24. Personal RMB businesses are launched. (HKMA)

February 25. Participating banks in the Hong Kong SAR can establish RMB-denominated 

accounts, accept RMB deposits, provide RMB–Hong Kong dollar exchange service, and effect 

RMB remittances for residents and specified commercial customers in Hong Kong. (AREAER

2004, 229, “Arrangement for payments and receipts” change)

February 25. The number of primary dealers for open market operations is raised by the PBC 

after some securities companies, insurance companies, and rural credit cooperatives unions were 

approved as primary dealers. (PBC)

April 1. The amount for which documentary evidence is required in order to surrender foreign 

exchange is raised to the equivalent of $50,000 from $20,000. (AREAER 2004, 229, “Proceeds 

from invisible transactions and current transfers” change)
109

May 1. The amount of previous current account foreign exchange income that qualifying 

enterprises are allowed to retain is increased to the equivalent of 30 percent or 50 percent from 

20 percent. (AREAER 2004, 229, “Exports and export proceeds” change)

May 1. The definition of qualifying enterprises is adjusted to include enterprises with specifically 

allowed foreign exchange business. Previously, the list included enterprises with specific foreign 

exchange volume or capital amounts. (AREAER 2004, 229, “Exports and export proceeds” 

change)

June 27. Foreign-funded domestic banks are not permitted to convert proceeds from debt 

contracted abroad into RMB and are not allowed to purchase foreign exchange for servicing such 

debts. (PBC)

June 27. Capital remitted as inward foreign direct investment can be converted into RMB only 

on the basis of a written payment order by the foreign-invested enterprise. (PBC)

August 12. The PBC puts forth clearing and reflow mechanisms for banking in RMB in the 

Macau SAR. (PBC)

September 8. Mainland China residents are allowed to use RMB-denominated bank cards for 

tourism-related payments in the Macau SAR. (AREAER 2005, 235, “Arrangement for payments 

and receipts” change)

November 1. The PBC allows qualified securities firms to issue short-term financing bills to 

qualified institutional investors in the interbank market. (PBC)

November 3. Participating banks in the Macao SAR are allowed to open RMB-denominated 

accounts; accept RMB deposits; provide exchange services between the RMB, the Hong Kong 

dollar, and the Macao pataca; and effect RMB remittances for residents and designated 

commercial customers in the Macao SAR. (AREAER 2005, 235, “Arrangement for payments and 

receipts” change)

November 17. The China Development Bank is approved for the issuance of bonds with floating 

interest rates around the seven-day repo benchmark rate on the interbank market. (PBC)

December 1. Foreign heirs, including those from Hong Kong and Macau, are permitted to take 

inheritances out of the country. Emigrants are allowed to take legally obtained personal assets up 

to the equivalent of $200,000; for larger amounts, staggered transfers are required to be made 

over a minimum period of two years. (PBC)

December 28. For the first time, the PBC issues forward central bank bills. (PBC)

Changes during 2005

January 1. The limit on the amount of RMB that a domestic or foreign resident can bring in and 

out of China per time is increased to RMB 20,000 from RMB 6,000. (PBC)
110

January 1. Persons paying for their own studies abroad are allowed to purchase foreign exchange 

up to $20,000 in addition to tuition and fees. The amount had been $20,000, including tuition and 

fees. (AREAER 2006, 300, “Payments for invisible transactions and current transfers” change)

January 10. Residents of mainland China may use certain RMB-denominated bank cards for 

purchases in Thailand and for withdrawing cash and making purchases in Korea and Singapore. 

(AREAER 2006, 300, “Arrangements for payments and receipts” change)

January 15. The reserve requirements on accounts denominated in domestic and foreign 

currency are unified at 3 percent. (AREAER 2006, 300, “Provisions specific to commercial banks 

and other credit institutions” change)

February 18. The PBC and other government ministries announce that international development 

organizations that are eligible can issue RMB-denominated bonds. (PBC)

April 6. A pilot program intended to allow commercial banks to set up fund management firms is 

announced. (PBC)

April 30. The PBC approves the Pan-Asian Index Fund’s access to the interbank bond market in 

China, making it the first institutional investor outside China to do so. (PBC)

May 18. The interbank foreign exchange market formally offers foreign currency trading. The

China Foreign Exchange Trading System (CFETS) offers trading of eight currency pairs. (PBC)

June 15. The PBC allows forward bond transactions on the interbank bond market. (PBC)

June 17. Notice that would allow insurance companies to invest in overseas stock markets is 

issued. (PBC)

August 2. The number of banks allowed to conduct forward transactions and interbank forward 

transactions is expanded, and restrictions on maturity are lifted. (AREAER 2006, 299, “Exchange 

arrangement” change)

August 2. Domestic institutions that are allowed to conduct current account transactions can 

retain foreign exchange equivalent to 50 percent (previously 30 percent) or 80 percent 

(previously 50 percent) of their foreign exchange earnings from current transactions in the 

previous year; domestic institutions or enterprises that had no current foreign exchange income 

in the previous year could retain up to the equivalent of $200,000 (previously $100,000). 

(AREAER 2006, 300, “Exports and export proceeds” change)

August 2. The PBC starts RMB swaps on the foreign exchange market. (PBC)

August 3. Limits on foreign exchange purchases for private travel are increased: (1) If travel is 

for six months or less, the limit is increased to the equivalent of $5,000 from $3,000; (2) if travel 

is for a period exceeding six months, the limit is increased to $8,000 from $5,000. (AREAER

2006, 300, “Payments for invisible transactions and current transfers” change)
111

August 9. The PBC starts a credit asset and mortgage loan securitization pilot program, for which 

the China Construction Bank and the China Development Bank are chosen as pilot institutions. 

(PBC)

August 15. Interbank foreign exchange forward trading products are introduced by the CFETS. 

The Industrial and Commercial Bank of China and the China Construction Bank complete two 

forward deals of the U.S. dollar against the RMB on the same day. (PBC)

August 16. The SAFE issues a notice that allows annual balance control to replace the case-bycase approval used when domestic banks designated for foreign exchange make guarantees for 

Chinese companies engaged in investment overseas. This system now applies to all banks 

designated as qualified for domestic foreign exchange, and all qualified domestic institutions’ 

foreign investment enterprises can now accept domestic guarantees. (SAFE)

August 30. The State Council approves a policy that allows commercial banks to invest in assetbacked securities. (PBC)

September 22. The SAFE issues notice to extend the coverage of foreign exchange trading 

positions. (SAFE)

October 9. The Asian Development Bank and the International Finance Corporation are 

approved for the issuance of RMB-denominated bonds valued at RMB 1 billion and RMB 1.13 

billion, respectively, on the interbank bond market, marking the first time that foreign 

institutional investors participate in the Chinese bond market. (PBC)

November 1. The PBC expands its position-squaring and clearing services to Hong Kong banks 

conducting RMB businesses in order to meet RMB business development needs. Furthermore, 

the PBC also expands RMB business for Hong Kong residents and raises cash exchange limits.

(PBC)

December 5. RMB-denominated cards may be used in France, Germany, Indonesia, 

Luxembourg, the Philippines, Spain, the United States, and Vietnam. (AREAER 2006, 300, 

“Arrangements for payments and receipts” change)

December 8. The PBC approves the China Construction Bank and China Development Bank’s 

pilot issuance of asset-backed securities on the interbank market. (PBC)

December 13. The PBC issues a circular to streamline administrative procedures, expand the 

investor base, and increase market transparency in the corporate bond market. (PBC)

December 15. RMB-denominated cards may be used in Belgium and Japan. (AREAER 2006, 

300, “Arrangements for payments and receipts” change)

December 18. The number of banks permitted to be market makers is increased from 13 to 21. 

(AREAER 2006, 272, “Exchange arrangement” change)
112

Changes during 2006

January 4. Over-the-counter transactions and market makers are offered on the interbank foreign 

exchange market. (PBC)

January 24. The PBC announces pilot RMB interest rate swaps on the interbank market. (PBC)

March 10. The CFETS and the Chicago Mercantile Exchange (CME) sign an agreement that 

provides China’s financial sector with access to the electronic trading of CME’s interest rate and 

foreign exchange products. (PBC)

April 13. Domestic banks’ overseas foreign exchange fund-management services for customers 

is expanded; qualified banks are allowed to combine RMB funds of domestic institutions and 

individuals and purchase foreign exchange within limits to invest in fixed-income products 

abroad; qualified fund-management firms and other securities firms are allowed to combine 

(within limits) foreign exchange funds of domestic institutions and individuals for overseas 

portfolio investments, including for stocks; insurance institutions’ securities investment business 

abroad is expanded; qualified insurance companies are allowed to purchase foreign currency to 

invest in fixed-income products and currency market instruments abroad, with the foreign 

exchange purchase amount subject to a certain proportion of the insurance institution’s total

assets. (PBC)

April 15. On approval, qualified fund management firms and other securities management 

companies now may, within a certain limit, combine foreign exchange funds owned by domestic 

institutions and individuals and use the funds overseas for portfolio investments, including for 

stocks. (AREAER 2007, 273, l, qualified fund management firms and other securities 

management companies change)

May 1. Residents are now allowed to purchase foreign exchange up to $20,000 a year for current 

account transactions. (AREAER 2007, 272, “Payment for invisible transactions and current 

transfers” change)

July 1. The limit on the amount of foreign exchange used in Chinese enterprises’ direct 

investments abroad is abolished. (PBC)

July 6. The PBC issues a circular that allows brokerage business on the interbank bond and 

lending markets. (PBC)

September 1. Nonresidents may purchase domestic real estate based on actual needs and for their 

own use. (PBC)

September 1. The Interim Implementing Regulations on QFII Securities Investments in China is 

abolished, and the administration of QFII investments in China starts. (AREAER 2007, 273, 

“Provisions specific to institutions investors” change)
113

October 20. Any foreign exchange transaction that is eligible for spot settlement under the 

regulations becomes eligible for forward settlement. (AREAER 2007, 272, “Exchange 

arrangement” change)

December 11. China provides full national treatment for foreign banks. Under its World Trade 

Organization agreement, foreign banks, after being incorporated locally, are permitted to engage 

in the same range of financial services as Chinese banks, including taking retail RMB deposits, 

and they are regulated and supervised in the same way as domestic banks. Foreign bank branches 

that have the China Banking and Regulatory Commission’s approval to conduct RMB business 

may accept fixed-term deposits from Chinese citizens living in China in the amount of no less 

than 1 million RMB per transaction. (AREAER 2007, 272, “Provision specific to commercial 

banks and other credit institutions” change)

December 29. The CFETS founds its own clearinghouse in order to better control clearing risks 

and improve market liquidity. (PBC)

Changes during 2007

January 4. The Shanghai Interbank Offered Rate (SHIBOR) is officially launched. (PBC)

January 14. The PBC allows domestic financial institutions to issue RMB financial bonds in 

Hong Kong, subject to approval. (PBC)

January 15. The number of market-maker banks is increased from 21 to 22. (AREAER 2007, 

273, “Exchange arrangement” change)

February 1. The limit on foreign exchange purchases by residents for current transactions is 

increased to $50,000 a year from $20,000. Resident individuals’ foreign exchange purchases up 

to this limit are processed with personal identification and, after bank declarations, foreign 

exchange purchases in excess of this limit may be processed after bank verification of actualneed documents stipulated by the SAFE. (AREAER 2008, 321, “Payment for invisible 

transactions and current transfers” change)

February 1. The limit on foreign exchange purchases by residents for remittances abroad for 

personal reasons is increased to $50,000 a year. Resident individuals’ foreign exchange receipts 

up to $50,000 may be processed with a bank on proof of identity. (SAFE)

March 2. The SAFE reduces the 2007 short-term external debt quotas of Chinese-funded banks 

to 30 percent and those of nonbank financial institutions and foreign-funded banks to 60 percent 

of their 2006 equivalents. In addition, Chinese-funded banks are required to reduce their 

outstanding short-term external debts to 30 percent or less and nonbank financial institutions and 

foreign-funded banks to 60 percent or less of their 2006 quotas by March 31, 2008. (SAFE)

March 20. A notice that allows corporate annuity funds access to the interbank bond market is 

issued. (SAFE)
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April 9. The CFETS puts forth a new trading platform that synthesizes RMB spot, forward, and 

options transactions against other currencies plus pair transactions among foreign currencies. 

(PBC)

June 7. The Shanghai Gold Exchange obtains the PBC’s approval to admit operational units of 

foreign banks as its members. (PBC)

June 26. RMB bond issuance starts in Hong Kong. (PBC)

July 5. The Qualified Domestic Institutional Investor (QDII) program starts. (PBC)

August 12. Domestic institutions are now allowed to retain foreign exchange receipts from 

current account transactions in their foreign exchange current accounts according to their 

operational needs. The previous limits on the retention of foreign exchange receipts are 

eliminated. (AREAER 2008, 321, “Exports and export proceeds” change)

August 17. RMB swaps against the U.S. dollar, the euro, the yen, the Hong Kong dollar, and the 

pound sterling are introduced in the interbank foreign exchange market. (PBC)

August 20. The SAFE initiates a pilot program that allows domestic residents to invest in 

securities overseas under controllable risks. (PBC)

August 30. The SAFE fully decentralizes the task of verification of sources of foreign exchange 

capital for outward investment. SAFE branches are authorized to verify sources of foreign 

exchange capital for outward investment projects of $10 million or more. (SAFE)

September 3. The National Association of Financial Market Institutional Investors—which 

includes members of the interbank market, foreign exchange market, and gold market—is 

formed. (PBC)

September 29. The PBC introduces forward rate agreements. (PBC)

December 9. The overall QFII quota was raised to $30 billion from $10 billion. (SAFE)

Changes during 2008

January 18. The PBC fully authorizes interest rate swaps. (PBC)

March 7. Regulated financial institutions that meet risk-management requirements are allowed to 

trade in gold futures on the domestic market. (SAFE)

July 14. The registration management system for the provision of trade credit between residents 

and nonresidents is implemented for advance receipts of export payments. (SAFE)

July 25. The China Domestic Foreign Currency Payment System is started. (PBC)
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August 5. The foreign exchange income of domestic institutions and individuals is now allowed 

to be deposited abroad, under the terms and conditions specified by the Foreign Exchange 

Administration Department; however, these regulations have not yet been issued. (AREAER

2009, 539, “Exports and export proceeds” change)

August 20. The SAFE approves a pilot program to allow for individual domestic and foreign 

currency exchange business in Beijing and Shanghai, subject to approval. (PBC)

August 29. The amount of capital remitted as inward foreign direct investment that may be 

converted to RMB only with a written payment order by the company making the foreign 

investment is reduced to $50,000 from $200,000. (SAFE)

August. The ceiling on the initial investment amount for each new institutional investor is raised 

to $1 billion from $800 million. (Lardy and Douglass 2011, 11)

October 1. The registration management system for the provision of trade credit between 

residents and nonresidents is implemented for deferred payments of imports. (SAFE)

November 15. The registration management system for the provision of trade credit between 

residents and nonresidents is implemented for advance receipts of import payments. (SAFE)

December 1. The registration management system for the provision of trade credit between 

residents and nonresidents is implemented for deferred payments of exports. (SAFE)

December 9. CBRC allows commercial banks to provide loans to firms for cross-border mergersand-acquisitions purposes (Lardy and Douglass, 2011).

Changes during 2009

January 7. The PBC eliminates restrictions that previously stipulated that a bond must exceed 

RMB 500 million in value to be traded on the interbank bond market. (PBC)

March 12. The Ministry of Commerce announces new rules regarding project approval that seek 

to shorten the time to gain approval, raise value thresholds, and boost discretionary power of the 

ministry’s local branches (Lardy and Douglass 2011).

March 16. The PBC and HKMA start a cross-border multicurrency payment arrangement.

(HKMA)

March 17. The SAFE announces the “Notice on the Decision on Short-Term External Debt 

Quotas for Financial Institutions in 2009,” which raises the short-term debt quotas of financial 

institutions. (PBC)

March 18. The PBC now allows fund management companies to open bond accounts on the 

interbank bond market under the category of a specific asset management portfolio. (PBC) 
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April 8. The State Council announces a pilot program that allows exporters and importers in five 

cities—Shanghai, Guangzhou, Shenzhen, Zhuhai, and Dongguan—to settle cross-border trade 

deals in RMB. (PBC)

May 14 and June 24. The PBC approves the Bank of East Asia (Hong Kong)’s and the Hong 

Kong and Shanghai Banking Corporation (China)’s issuance of RMB 4 billion and RMB 3 

billion, respectively, in RMB-denominated bonds in Hong Kong. (PBC)

July 2. RMB cross-border trade settlement starts in pilot cities. (PBC)

August 1. The protocol for review of the source of foreign exchange funds for outward direct 

investment changes from ex-ante examination to ex-post registration, and the review and 

approval requirement for outward remittances of funds for outward direct investments is 

canceled. During the preparatory stage before the formal startup of the foreign project, with 

SAFE approval, domestic institutions may remit a certain percentage of the total investment 

abroad. (SAFE)

September 28. The Ministry of Finance of China announces the issuance of the first sovereign 

RMB-denominated bond in Hong Kong. (HKMA)

September 29. With respect to QDII, the net amount of funds remitted abroad by securities 

dealers for investment in securities abroad must not exceed approved investment limits. (SAFE)

September 29. The upper limit on individual QFII investments was raised from $800 million to 

$1 billion, and the principal lock-up period for medium- and long-term investments by pension 

funds, insurance funds, and open-end funds is decreased to 3 months from 6 to 12 months; the 

principal lock-up period for other institutions was decreased from three years to one year.

(CSRC) 

November 28. The Interbank Market Clearing House Co., Ltd., is formally established in 

Shanghai. (PBC) 

December 14. The PBC broadens the range of transactions for which it provides RMB position 

squaring and clearing for banks in Macau. (PBC)

Changes during 2010

March 24. The PBC and the National Bank of the Republic of Belarus sign a bilateral local 

currency settlement agreement. This represents the first such agreement for general trade 

transactions that China has signed with a non-neighboring country. (PBC)

June 22. The PBC, along with other ministries, jointly announces the “Notice on Expansion of 

the Pilot RMB Settlement of Cross-Border Trade Program.” This measure broadens the 

geographic coverage of the RMB-settlement pilot program. Cross-border settlement business is 

also expanded beyond trade items to other balance of payment items. Current account 
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transactions between 20 provinces and cities on the mainland and the rest of the world may now 

be settled in RMB. Previously, transactions had to be settled in convertible currencies. (PBC)

July 7. Hopewell Highway Infrastructural Ltd. announces the issuance of RMB-denominated 

bonds in Hong Kong, marking the first corporate dim sum bond issuance. (Financial Times)

July 13. The Bank of China (Hong Kong) is authorized to serve as the clearing bank for RMB

banknotes in Taiwan. (PBC) 

July 19. Financial institutions in the Hong Kong SAR—including banks, securities brokerages,

and insurance companies—are now allowed to open RMB accounts. In addition, individuals and 

corporations can now undertake payments and transfers of RMB between these banks and 

interbank settlement in RMB. To facilitate the use of the RMB in trade transactions, foreign 

banks engaged in such settlements were allowed to open RMB correspondent accounts with 

Chinese banks as of July 2009. (AREAER 2011, 631, “Nonresident Accounts” Change)

August 17. Foreign central banks, monetary authorities, Hong Kong SAR and Macau SAR RMB 

clearing banks, and foreign banks engaged in RMB trade-clearing are allowed to invest in the 

China interbank bond market. These investments have several limitations, but there is no 

minimum holding period. (SAFE)

August 19. McDonald’s announces the issuance of RMB bonds worth RMB 200 billion, marking 

the first issuance of RMB bonds by a multinational corporation. (Financial Times)

October 1. Nonresident nonbank institutions accepting payments for exports to China in RMB

are now allowed to deposit the proceeds from such transactions in correspondent accounts with 

Chinese mainland banks. Limited trade financing is also possible through the correspondent 

accounts. (AREAER 2011, 632, “Nonresident accounts” change)

October 1. Pilot projects for the depositing of export proceeds abroad are launched in four areas: 

Beijing, Guangdong (including Shenzhen), Shandong (including Qingdao), and Jiangsu. Eligible 

domestic enterprises in pilot project areas may apply to local SAFE branches to deposit export 

proceeds abroad and, on approval, participate in the pilot projects. In accordance with the 

relevant regulations, the opening and closing of external accounts and funds receipts and 

payments must be processed and the relevant information reported to the SAFE. (AREAER 2011, 

632, “Exports and export proceeds” change)

November 22. The PBC authorizes the CFETS to set up direct Russian ruble trading with the 

RMB on the interbank foreign exchange market. (PBC)

November 22. Issuances of RMB-denominated sovereign bonds are conducted through the 

Central Moneymarkets Unit. (HKMA)

November 24. The U.S. multinational Caterpillar announces the issuance of RMB 1 billion worth 

of RMB-denominated bonds. (Financial Times)
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December 8. The number of Chinese exporters allowed to participate in RMB settlement is 

increased from 365 to 67,359. (PBC)

December 15. The Russian Moscow Interbank Currency Exchange starts RMB–ruble trading. 

(PBC)

December 31. The “Bank of China (Hong Kong) Offshore RMB Bond Index,” the first Hong 

Kong RMB bond index, is launched. (Bank of China)

Changes during 2011

January 1. The SAFE classifies foreign exchange market makers into three types to increase 

liquidity in China’s foreign exchange market and boost its development: spot-trading market 

makers, forwards and swap-trading market makers, and comprehensive market makers. Twentysix banks have been approved as spot market makers, and 18 have been approved as forward 

swap market makers. (AREAER 2011, 632, “Exchange arrangement” change)

January 6. Resident enterprises in 20 provinces and cities on the mainland are now allowed to 

use RMB for outward foreign direct investment in countries that accept such settlement. 

Previously, such payments had to be settled in convertible currencies. Banks in Hong Kong can 

provide RMB funds to facilitate these transactions. (AREAER 2011, 632, “Arrangements for 

payments and receipts” change, HKMA) 

January 13. The Bank of China is approved to set up RMB-denominated deposit accounts in 

New York City. (PBC)

January 24. The Qualified Limited Foreign Partner (QLFP) pilot program starts in Shanghai. 

(Government of Shanghai)

February 14. The PBC allows RMB-FOREX options trading on the interbank foreign exchange 

market. (PBC)

June 23. The PBC signs a new bilateral local currency settlement agreement with the Central 

Bank of the Russian Federation. (PBC)

August 23. Cross-border trade settlement in RMB is extended to the entire nation. (PBC) 

September 14. HSBC announces that it has become the first foreign bank to offer RMB services 

and products in Taiwan. (HSBC)

Third quarter. RMB-denominated corporate bond issuance exceeds that of euro-denominated 

sales for the first time. (Financial Times, September 29, 2011)

October 12. Foreign investors are permitted to engage in direct investment activities in China 

using RMB obtained legally abroad. (SAFE)
119

October 14. The PBC announces rules that permit banks to provide settlement services to 

overseas entities that have made direct investments denominated in RMB. (PBC)

October 16. The Chinese Gold & Silver Exchange launches the world’s first RMB-denominated 

gold contract in Hong Kong. (CNBC, October 16)

October 17. The Ministry of Commerce issues an announcement that allows foreign direct 

investment in RMB from outbound investors. (Ministry of Commerce)

November 10. The PBC signs an agreement with the Austrian Central Bank to allow the latter to 

invest in the interbank bond market in China. (PBC)

November 28. JP Morgan Asset Management is allowed to create a $1 billion RMB-denominated 

fund under the Qualified Limited Partners Program, making it the largest foreign manager of an

RMB-denominated fund so far. (JP Morgan)

December 16. Offshore RMB are allowed to be used for purchasing equities in mainland China.

(Financial Times)

December 16. On the basis of the existing system, some QFIIs are further permitted by a pilot 

project to invest in the domestic securities market using RMB; the first group of pilot institutions 

comprises Hong Kong subsidiaries of qualified Chinese domestic fund management companies 

and securities companies. (SAFE)

December 25. China and Japan agree to promote local currency cross-border transactions, direct 

foreign exchange, bond market development, and other programs. (PBC)

Changes during 2012

March 1. The PBC releases regulations allowing all China-based enterprises with import and 

export qualifications to settle their goods exports in RMB. (PBC)

March 28. The State Council of China approves Wenzhou, Zhejiang province for a pilot program 

that allows residents in the city to spend up to $200 million a year—or as much as $3 million a 

person—to set up, acquire, or invest in non-financial companies in foreign markets. (State 

Council)

April 2. CSRC increased the quotas for QFII to $80 billion from $30 billion and for RQFII to 

RMB 70 billion from the previous limit of RMB 20 billion. (CSRC)

April 16. The floating band of the RMB’s trading prices against the U.S. dollar in the interbank 

foreign exchange market was widened from 0.5 percent to 1 percent—i.e., on each business day, 

the trading prices of the RMB against the U.S. dollar in the interbank foreign exchange market 

may fluctuate within a band of ±1 percent around the central parity released on the same day by 

the CFETS. The spread between the highest offer price and the lowest bid price of RMB–U.S. 

dollar spot transactions, as quoted by foreign-exchange-designated banks to their customers, may 
120

not exceed 2 percent of the central parity (previously 1 percent). (AREAER 2012, 671, 

“Exchange rate arrangement” change)

April 19. The British multinational banking firm HSBC issues the first offshore RMB bonds in 

London. (HSBC)

May 29. Direct trading between the RMB and the Japanese yen is launched. (Reuters)

May 29. The Hong Kong Securities and Futures Commission (SFC) approved the introduction of 

the first RMB currency futures in Hong Kong. (SFC)

June 15. HKMA introduces the 1-week Liquidity Facility to banks in Hong Kong. (HKMA)

June 27. The State Council of China approves policies supporting the financial testing zone in 

Qianhai, Shenzhen for the offshore CNY market, with liberalization of capital account 

convertibility. (State Council)

June 29. CSRC and the Hong Kong Securities and Futures Commission (SFC) authorize listing 

in Hong Kong of the first RMB RQFII A-share ETFs, RMB-denominated products that will 

track mainland indexes and trade in Hong Kong. (SFC)

July 27. CSRC issues new provisions relaxing entry requirements for the QFII, under which 

international fund managers with as little as $500 million under management and two years’ 

operating history are eligible to apply for QFII quotas. (CSRC)

August 1. HKMA allows Hong Kong banks to provide RMB service to nonresidents. (HKMA)

December 11. Bank of China (Taipei branch) is named the clearing bank for RMB in Taiwan. 

(Bank of China)

December 14. The SAFE releases a set of guidelines that raise the ceiling of the investment 

quota of institutional investors such as sovereign wealth funds, central banks, and monetary 

authorities above USD 1 billion or equivalent. (SAFE)

December 17. On liquidation of direct investment, a foreign investor may directly execute the 

purchase of foreign currency and repatriation of funds at the relevant bank, after registration with 

the SAFE. (The related approval procedures for the purchase of foreign currency and repatriation 

of funds are eliminated.) (SAFE)

December 17. Nonresidents may repatriate proceeds from real estate sales directly at the relevant 

bank, after registration with the SAFE. (The foreign currency approval procedures are 

eliminated.) (SAFE)

December 27. The PBC approves cross-border RMB loans in Shenzhen, granting Chinese 

companies access to borrow RMB from Hong Kong-based banks. (PBC)
121

Changes during 2013

January 25. The PBC signs an agreement with Taiwan permitting direct settlement of RMB

payments between China and Taiwan. The agreement also extends the RQFII program to Taiwan 

with investment quota of up to RMB 100 billion ($19.7 billion). (PBC)

February 7. Proceeds from the issuance of shares by an overseas-listed enterprise controlled by 

foreign shareholders may, after registration, be retained overseas. Foreign exchange funds earned 

by the domestic equity holding unit of overseas-listed companies controlled by Chinese 

shareholders from sales of shares or assets of the listed company must be repatriated within two 

years of receipt. Previously, such proceeds were required to be repatriated within six months of 

receipt, which could be extended to two years with SAFE approval. (SAFE)

February 8. The Industrial and Commercial Bank of China is named the clearing bank for 

offshore RMB business in Singapore. (PBC)

March 1. Under the expanded RMB RQFII program, Hong Kong subsidiaries of Chinese banks 

and insurers as well as financial institutions registered and operating in Hong Kong SAR may 

invest in domestic securities markets using RMB proceeds raised in Hong Kong SAR. The 

restriction on asset allocation under the program is also relaxed, permitting RMB-qualified 

foreign institutional investors to invest in a wider variety of financial instruments. (AREAER

2013, 622, “Exchange arrangement” change)

March 26. The PBC signs a bilateral local currency swap arrangement with Banco Central do 

Brasil valued at about RMB 190 billion or 60 billion real. (PBC)

June 21. RQFIIs in the Taiwan region are allowed to invest in mainland securities markets. 

(AREAER 2013, 622, “Exchange arrangement” change)

June 22. The PBC and the Bank of England reach a three-year currency swap with the value 

exceeding RMB 200 billion ($32.6 billion). (PBC)

June 24. The Hong Kong Treasury Markets Association (TMA) launches the new CNH Hong 

Kong Interbank Offered Rate fixing, with 16 banks elected for contribution of the interest rate 

quotes. (HKMA)

July 12. The overall investment limit for QFIIs is increased from $80 billion to $150 billion. 

(AREAER 2013, 622, “Capital transactions” change)

September 29. China officially launches the China (Shanghai) Pilot Free Trade Zone. (State 

Council)

October 10. The PBC and the European Central Bank agree to establish a bilateral currency swap 

line with maturity of three years and with a maximum size of RMB 350 billion or 

45 billion euros. (PBC)
122

October 15. RQFII in the United Kingdom are allowed to invest in mainland securities markets. 

(AREAER 2013, 622, “Exchange arrangement” change)

October 22. RQFII in Singapore are allowed to invest in mainland securities markets. (AREAER

2013, 622, “Exchange arrangement” change)

November 6. Canada’s western province of British Columbia issues one-year offshore RMBdenominated bonds and raises RMB 2.5 billion, the first time a foreign government has issued 

offshore RMB bonds. (Caixin Media)

Changes during 2014

January 10. The requirement to verify underlying documents is canceled for profit repatriation 

less than $50,000. For larger amounts, banks must verify board of directors’ resolutions on the 

distribution of profits (or partners’ resolution on the distribution of profits) and the originals of 

the tax filing forms. (AREAER 2014, 726, “Capital transactions” change)

January 10. Restrictions on the purpose and maturities of offshore lending are relaxed. (AREAER

2014, 726, “Capital transactions” change)

February 19. The book value of consolidated foreign and domestic real estate-type investments 

is increased from 20 percent to 30 percent of an insurance company’s total assets at the end of 

the previous quarter; total book value does not include real estate purchased with insurance 

companies’ own funds for their own use, whose book value balance may not exceed 50 percent 

of their total net assets at the end of the previous quarter. The book value of a single investment 

in fixed-income assets, equity, or real estate may not exceed 5 percent of the insurance 

company’s total assets at the end of the previous quarter. A single investment in the same legal 

entity may not exceed in total 20 percent of an insurance company’s total assets at the end of the 

previous quarter. (AREAER 2013,623, “Capital transactions” change)

February 19. The limit on the investments of an insurance company in foreign and domestic real 

estate is increased from 20 percent to 30 percent of the insurance company’s total assets at the 

end of the previous quarter. The total balance does not include real estate purchased with 

insurance companies’ propriety funds for their own use, the balance of which may not exceed 50

percent of their total net assets at the end of the previous quarter. A single investment in real 

estate is set at 5 percent of the insurance company’s total assets at the end of the previous 

quarter. (AREAER 2014, 726, “Capital transactions” change)

February 21. The PBC releases notices allowing cross-border RMB cash pooling, sweeping, 

borrowing, and centralized settlement and netting within the zone. (PBC) 

March 13. The China Development Bank issues RMB 1 billion of 3-year RMB bonds in Hong 

Kong at an interest rate of 3.35 percent and 1.87x subscriptions ratios. (China Development 

Bank)
123

March 17. The floating band of the RMB’s trading prices against the U.S. dollar in the interbank 

foreign exchange market is widened from 1 percent to 2 percent. That is, on each business day, 

the trading prices of the RMB against the U.S. dollar in the market may fluctuate within a band 

of ±2 percent around the central parity released that day by the CFETS. The range of the spread 

between the highest offer price and the lowest bid price for RMB–U.S. dollar spot transactions at 

foreign-exchange-designated banks and their customers is widened from 2 percent to 3 percent 

of the central parity. (AREAER 2013, 623, “Exchange arrangement” change)

March 19. The interbank foreign exchange market launches direct trading of the RMB against 

the New Zealand dollar. (AREAER 2013, 623, “Exchange arrangement” change)

March 28. The PBC signs an agreement with Germany’s Bundesbank to establish RMB clearing 

service in Frankfurt. (PBC)

March 31. The Bank of England signs an agreement with the PBC to enable the clearing and 

settlement of RMB transactions in London. (PBC)

May 12. Limitations on cross-border guarantees by residents and nonresidents (both inward and 

outward) are canceled. (AREAER 2014, 726, “Capital transactions” change)

June 11. RMB settlement of export transactions is simplified. Banks are allowed to settle exports 

in RMB based on the three principles of “know your customer,” “know your business,” and 

“conduct due diligence,” relying on the income and payment instructions submitted by the 

domestic enterprises. (AREAER 2014, 726, “Capital transactions” change)

June 11. Individuals may use RMB to settle international trade in goods and services. (AREAER

2014, 725, “Imports and import payments” change)

June 11. RMB settlement of import transactions is simplified. Banks are allowed to settle 

imports in RMB based on the three principles of “know your customer,” “know your business,” 

and “conduct due diligence,” relying on the income and payment instructions submitted by the 

domestic enterprises. (AREAER 2014, 725, “Exchange rate arrangement” change)

June 18. The PBC appoints the China Construction Bank to clear RMB-related transactions in 

London. (PBC)

June 18. The PBC announces that RMB can now be exchanged directly for British pounds in 

Shanghai’s foreign-exchange market. (PBC)

June 18. The PBC appoints the Bank of China (Frankfurt) as the first institution conducting 

RMB clearing business in Euro area. (PBC)

June 28. The PBC sets up RMB clearing centers in Paris and Luxembourg. (PBC)
124

July 3. The PBC and the Bank of Korea sign an MOU on Establishing RMB Clearing 

Arrangements in Seoul, with the Bank of Communications named as the clearing bank in South 

Korea. (PBC)

July 3. The PBC and the Central Bank of Argentina renew the three-year deal on their 

bilateral local currency swap. The size of the swap facility is RMB 70 billion (90 billion 

Argentina pesos). (PBC)

July 9. China grants a RQFII quota of RMB 80 billion ($12.9 billion) to Germany and South 

Korea, respectively. (CSRC)

July 14. The foreign exchange administration of round-trip investment is reformed and the 

registration of financing and changes in financing is canceled. (AREAER 2014, 726, “Capital 

transactions” change)

July 14. The middle rate of the RMB against the pound sterling is determined based on the 

average of the day’s market makers’ quotes. Previously, the rate was determined through the 

cross-rates by the CFETS based on the day’s middle rate for the RMB against the U.S. dollar and 

the exchange rates for the U.S. dollar against the pound sterling. (AREAER 2013, 623, 

“Exchange arrangement” change)

July 14. The PBC allows banks to set exchange rate quotes for their clients based on supply and 

demand in the market (PBC No. 2014/188). Previously, the difference between the maximum 

cash selling prices offered and the minimum cash buying prices of the RMB against the U.S. 

dollar could not exceed 4 percent of the daily middle rate. The difference between the highest 

spot exchange (cash) selling price and the lowest spot exchange (cash) buying price had to 

contain the day’s middle rate. Within the official spread range, banks can independently decide 

the buying and selling prices for spot and cash transactions. (AREAER 2013, 623, “Exchange 

arrangement” change)

July 21. The PBC and the Swiss National Bank sign a three-year currency swap agreement for 

RMB 150 billion (CHF 21 billion). (PBC)

September 11. The World Bank issues $1.25 billion worth of RMB bonds. (World Bank)

September 26. Foreign nonfinancial enterprises are allowed to use RMB raised through the 

issuance of RMB-denominated debt instruments in the domestic market in China and abroad. 

(AREAER 2014, 726, “Capital transactions” change)

September 26. RMB funds raised abroad are allowed to be used for debt servicing. (AREAER

2014, 726, “Capital transactions” change)

September 29. The PBC allows the CFETS to launch direct trading of RMB for euro and vice 

versa on the interbank foreign exchange market. (PBC)
125

October 14. The U.K. government issues a sovereign bond in RMB, becoming the first Western 

country to do so and issuing the largest ever non-Chinese RMB bond. The RMB 3 billion bond, 

which is equivalent to approximately £300 million, had a maturity of 3 years. (U.K. government)

October 24. The Asian Infrastructure Investment Bank (AIIB) is officially launched in 

Beijing. As of April 15, 2015, almost all Asian countries and most major countries outside Asia 

have joined the AIIB, except the United States, Japan, and Canada. North Korea’s and Taiwan’s 

applications for Prospective Founding Member (PFM) were rejected. (AIIB)

October 28. The interbank foreign exchange market launches direct trading of the RMB for the 

Singapore dollar. The middle rate of the RMB against the Singapore dollar is determined based 

on the average of the day’s market makers’ quotes. Previously, the rate was determined through 

the cross-rates by the China Foreign Exchange Trading System based on the day’s middle rate of 

the RMB against the U.S. dollar and the exchange rates for the U.S. dollar against the Singapore 

dollar. (AREAER 2014, 725, “Exchange rate arrangement” change)

November 1. Limits and quotas on the total amount and on the share of various financial 

instruments in the investment portfolio are eliminated for QDIIs’ overseas RMB investments 

(Notice of the People’s Bank of China on Matters Concerning the Overseas Securities 

Investment by RMB Qualified Domestic Institutional Investors. (AREAER 2014, 726, “Capital 

transactions” change)

November 1. Transnational enterprise groups are allowed to carry out cross-border surplus and 

deficit funds transfers and allocation business between resident and external nonfinancial 

member enterprises, based on their own business and management needs. (AREAER 2014, 726, 

“Capital transactions” change)

November 4. China gives an RMB 30 billion ($4.9 billion) quota to Qatar under the RQFII 

program. (CSRC)

November 10. The HKMA announces a provision of RMB intraday liquidity to Authorized 

Institutions participating in RMB business in Hong Kong. (HKMA)

October 13. The central banks of Russia and China announce an agreement for ruble-RMB

currency swaps, with a total value of CNY 150 billion. (PBC)

October 27. Direct trading of RMB for Singapore dollars and vice versa is launched. (Xinhua 

News Agency)

November 14. China’s government issues two notices confirming capital gains tax 

exemptions for QFIIs, RQFIIs, and the Shanghai-Hong Kong Stock Connect Scheme. (Ministry 

of Finance)

November 17. The Shanghai–Hong Kong Stock Connect scheme is officially launched, allowing 

Hong Kong and overseas investors to trade eligible shares listed in Shanghai. However, only 

mainland institutional investors and individual investors who have RMB 500,000 in their 
126

investment and cash accounts are eligible to trade Hong Kong-listed shares. The northbound 

aggregate quota is set at RMB 300 billion, while the southbound aggregate is set at RMB 250 

billion. (CSRC and SEHK)

November 17. The PBC names the Bank of China to be the clearing bank for RMB transactions 

in Sydney. (PBC)

November 17. RQFII scheme gives Australian investors a quota to invest up to RMB 50 billion

($8.2 billion). (CSRC)

November 18. The PBC signs a bilateral local currency swap agreement with the Bank of 

Canada, with the size of the facility being RMB 200 billion (CAD $30 billion). (PBC)

December 15. The interbank foreign exchange market launches direct trading of the RMB for the 

Kazakhstani tenge. The daily RMB–tenge reference rate is determined by averaging the quotes 

from tenge-quoting banks by the China Foreign Exchange Trading System before the daily 

interbank foreign exchange market opens. (AREAER 2014, 725, “Exchange rate arrangement” 

change)

December 17. Approval requirements for outward direct investments except in sensitive 

countries, regions, and sensitive industries are cancelled and replaced with a filing system. 

(AREAER 2014, 726, “Capital transactions” change)

Changes during 2015

January 21. The PBC and the Swiss National Bank sign an MOU on the establishment of RMB 

clearing arrangements in Switzerland. The PBC also extends the RQFII program to Switzerland 

with a total investment quota of RMB 50 billion. (PBC)

January 28. Foreign RMB clearing banks are allowed to carry out bond repo business in the 

interbank bond market. (AREAER 2014, 727, “Arrangements for payments and receipts” change)

February 13. The foreign exchange registration of FDI and overseas direct investment is moved 

from the SAFE to the banks. (AREAER 2014, 727, “Capital Transactions” change)

February 26. The Silk Road Fund, registered on December 29, 2014 in Beijing as a limited 

liability company, and jointly sponsored by official foreign exchange reserves, China Investment 

Corporation (CIC), the Export-Import Bank of China, and the China Development Bank in 

accordance with the Company Law of the People’s Republic of China starts operation. (PBC)

March 30. Previous restrictions on the conversion of foreign exchange capital to RMB by 

foreign-owned enterprises are removed. (AREAER 2014, 727, “Capital Transactions” change)

May 5. RQFII program is expanded to include Luxembourg, with the initial investment quota of 

RMB 50 billion being assigned. (PBC)
127

May 25. The PBC and Central Bank of Chile sign an agreement on a three-year local currency 

swap facility valued as RMB 22 billion (2.2 trillion Chilean pesos). The two parties also sign an

MOU on establishing RMB clearing arrangements in Chile and agree to include Chile in the pilot 

RQFII program with an investment quota of RMB 50 billion. (PBC)

May 28. RMB clearing banks abroad and nonresident participating banks with quotas to invest in 

the interbank bond market are allowed to undertake repo business in the interbank bond market 

to fund offshore RMB business. The limit on financing through repos is tied to the bonds held 

onshore. (AREAER 2014, 727, “Capital Transactions” change)

June 11. The PBC publishes the 2015 Report on RMB Internationalization, the first report on 

this topic released by a Chinese government agency. The report lays out a set of plans to improve 

the international use of RMB, including the establishment of China International Payment 

System (CIPS), Shenzhen–Hong Kong stock connect, and Qualified Domestic Individual 

Investors (QDII2). (PBC)

June 27. The PBC and the Central Bank of Hungary sign an MOU on the establishment of RMB 

clearing arrangements in Hungary and the agency agreement for the PBC to manage the MNB’s 

investments in China’s interbank bond market. (PBC)

July 1. Domestic public placement fund products are allowed to be sold in the Hong Kong 

region, subject to approval. Hong Kong public placement fund products are allowed to be sold 

within the region, subject to approval. (AREAER 2014, 727, “Capital Transactions” change)

July 11. The SAFE issues a circular to allow foreign-invested enterprises to settle foreign 

exchange capital on a voluntary basis, giving enterprises the freedom to choose the timing for 

settlement of foreign exchange capital. (SAFE)

July 14. The PBC further opens up the interbank bond market for investment by foreign central 

banks, international financial institutions, and sovereign wealth funds with RMB funds by 

introducing a registration system, eliminating quotas, and expanding the authorized investments 

to a broad range of interest rate instruments. (PBC)

August 11. The PBC announces a change in the quotation policies of the central parity of RMB 

against the U.S. dollar, accompanied by the biggest one-day drop in the RMB/USD rate in two 

decades. According to the new policy, the quotes of central parity that market makers report to 

the CFETS daily before the market opens should refer to the closing rate of the interbank foreign 

exchange market on the previous day, in conjunction with supply and demand conditions in the 

foreign exchange market and exchange rate movement of the major currencies. (PBC)

September 17. The PBC signs an MOU with the Central Bank of Argentina, announcing the 

launch of the second offshore clearing arrangement in Latin America (after Chile). (PBC)

September 22. For the first time, the PBC allows two foreign commercial banks, HSBC and the 

Bank of China (Hong Kong), to issue RMB bonds in the interbank market in mainland China. 

(PBC)
128

Appendix C: Restrictions on Investment in the FTZs

The 2015 Negative List

The 2015 negative list covers all four free trade zones (FTZs). The list features a number of 

changes relative to the 2014 Shanghai FTZ negative list, but these changes are to a large extent 

due to some changes in classification and definitions. The 2015 list includes all the limitations 

and restrictions on foreign investment from other laws as well, making this version more 

comprehensive. The text below highlights some of the main elements of the list and also key 

areas where restrictions have been lifted.124

Agriculture, forestry, animal husbandry, and fishing

1. Foreign investors are prohibited from the following businesses: developing, raising, or 

breeding plants that are rare or unique to China; breeding or producing genetically 

modified seeds, crops, or animals; collecting genetic resources or crops without 

permission. 

2. Foreign investors are not allowed to be the controlling shareholders of companies 

developing new crops and seeds.

3. Foreign investors are not allowed to fish in Chinese waters without permission from the 

government. 

Mining

A number of restrictions on mining have been lifted, with only the following rules remaining:

1. Foreign investors are not allowed to explore or develop China’s exclusive economic 

zones or its continental shelf without permission from the government. Foreign investors 

are allowed to start companies to explore for gas and oil only by forming partnerships 

with investors in China Mining. Prospecting for rare earths, radioactive materials, 

tungsten, molybdenum, tin, antimony, and fluorite is prohibited. Prospecting is restricted 

for lithium, precious metals, and graphite.

Manufacturing

A number of restrictions in the manufacturing industry have been lifted, including those on the 

processing of rice, corn, edible oils, tea, alcohol, tobacco, and chemicals (now fully allowed). In 

the area of pharmaceuticals and health care, anesthesia and blood products are now allowed. The 

manufacturing of motorized vehicles remains sensitive, making up most restrictions in the 

manufacturing industry. The restriction on construction vehicles, motorcycles, and new energy 

vehicle batteries have, however, been lifted. Other restrictions are as follows:

 124 This appendix draws extensively on material from China Briefing, an online resource provided by 

Dezan Shira & Associates, and is supplemented with information from State Council documents that are 

available at: http://www.gov.cn/zhengce/content/2015-04/20/content_9627.htm. 
129

1. Aircraft, unmanned aerial vehicles, and helicopters: Requires Chinese controlling 

interest.

2. Finished cars: can be maximum 50 percent foreign-owned. Car parts manufacturing fully 

open to foreign investment.

3. Ships, ship engines, and marine engineering equipment: Requires Chinese controlling 

interest.

4. Rail transport equipment: Limited to a contractual or equity joint venture; for urban rail 

transport, 70 percent of the equipment used must be made in China.

5. Satellites for civilian use: Requires Chinese controlling interest.

6. Processing and smelting of rare earths, tungsten, molybdenum, tin, antimony: Limited to

a contractual or equity joint venture.

7. Processing radioactive material: Prohibited.

8. Chinese herbal medicine: Prohibited.

9. Ivory, tiger bones, and traditional Chinese handicrafts: Prohibited.

Electricity, heat, gas, and water

1. Chinese investors should be controlling shareholders in the construction and operation of 

nuclear power facilities. Only state-owned companies or companies controlled by stateowned capital are allowed to treat solid radioactive waste. 

2. China’s investors should be controlling shareholders in providing water, heat, and gas to 

cities with urban population greater than 500,000. 

3. China’s investors should control the construction and operation of electricity grids. 

Franchising 

A number of important sectors have seen their restrictions lifted. These include fertilizers, 

agricultural film (to cover greenhouses), the sale of petrol through petrol stations, and the sale of 

books, newspapers, and magazines. Remaining prohibitions include the sale of tobacco, lottery 

tickets, and the auctioning of cultural relics.

Transportation

Limitations on transportation remain largely in place. There are special requirements for foreign 

investment in sectors including highways, railways, waterways, air, general aviation, and civil 

airports. Prohibited areas include air control systems, postal service, or express delivery within 

China. 

Telecommunication and information technology

1. As with the Catalogue of Restricted Industries, value-added telecom services (except ecommerce) are restricted to maximum 50 percent foreign shareholding, and basic telecom 

services are limited to 49 percent.

2. It is prohibited to operate news web sites, online publications, online audiovisual 

programs, or other broadcasting of information on the Internet (except for music), and 
130

those sectors that have been liberalized due to China’s membership in the World Trade 

Organization.

3. It is prohibited to create and publish maps on the internet.

4. If a domestic entity cooperates with a foreign entity to create online news, this activity 

shall be subject to a National Security Review.

Crucially, with e-commerce exempted from the restricted industries, foreign investors can now 

set up e-commerce companies in Fujian, Guangdong, and Tianjin as well as Shanghai.

Finance

The new negative list has a detailed set of rules for investment in banks:

1. The shareholder(s) in a bank that is either wholly foreign-owned or a Sino-foreign joint 

venture must itself be a financial institution, and the controlling entity a commercial 

bank. The investor in a fully Chinese-owned bank or trust company must be a financial 

institution.

2. Only foreign banks may invest in Chinese rural commercial banks, rural cooperative 

banks, or rural credit cooperative unions.

3. The investor in a financial leasing company must itself be a financial leasing company.

4. The main capital contributor in a consumer finance company must be a financial 

institution.

5. The investor in a currency brokerage must itself be a currency brokerage.

6. The investor in a financial asset management company must itself be a financial 

institution, but may not be involved in the establishment of a new asset management 

company.

7. The investor in a financial institution will be subject to asset requirements—the negative 

list does not specify the amounts.

8. In addition, foreign banks may not conduct the following activities, as defined in 

the Commercial Banking Law: Acting as an agent to issue, honor, and 

underwrite government bonds; issuing bank cards; or acting as an agent for receipt and 

payments of funds. Apart from taking time deposits for Chinese nationals of less than 

RMB 1 million, foreign banks in China may not engage in RMB activities for Chinese 

nationals.

9. The parent company of a foreign-invested bank in China must provide its operational 

funds free of charge. The foreign-invested bank must operate with an 8 percent capital 

reserve. Banks providing RMB services must follow the minimum required business 

hours.

The requirements for financial companies other than banks focus mainly on equity restrictions:

1. Futures companies: Require Chinese majority interest.

2. Securities companies: Foreign investment may not exceed 49 percent of shares. In 

addition, for securities companies listed on the stock exchange, a single foreign entity 

may not hold over 20 percent of shares, and total foreign shareholding may not exceed 25 

percent.
131

3. Fund management: Foreign investment may not exceed 49 percent of shares.

4. Foreign entities may not become regular members of futures and securities exchanges, 

and may not open securities and futures accounts to trade A shares.

5. Life insurance: Foreign investment may not exceed 50 percent of shares.

6. Chinese insurance companies must hold at least 75 percent of shares in insurance asset 

management companies.

Leasing and commercial services

1. Accounting: The main partner must be a Chinese national.

2. Legal services: Foreign law firms may be present in China only through a representative 

office, which is subject to approval. Foreign nationals may not advise on Chinese law or 

become partners of a Chinese law firm. Representative offices of foreign law firms may 

not hire Chinese legal professionals, and its support staff may not provide legal advice.

3. Credit rating: Restricted.

4. Investment in polling and social surveys: Prohibited.

5. Market research is restricted to contractual or equity joint ventures, with the surveying of 

radio and television requiring Chinese controlling interest.

6. The legal representative of a visa agency must have Chinese nationality and domicile.

Hydraulic and environmental projects and management of public facilities 

1. Foreign investors are prohibited from projects involving the development of wildlife

native to China and under the country’s protection.

2. Foreign investors are also prohibited from collecting and purchasing wild plants that are 

on the national list. 

Education

1. Foreign entities may not independently establish schools and educational institutions 

enrolling mainly Chinese nationals (except for non-academic vocational training).

2. Foreign entities may establish and run educational institutions in cooperation with a 

Chinese party, under the following conditions:

a. Education must be unrelated to the military, law enforcement, politics, or political 

parties.

b. Foreign entities may not provide religious education.

c. Regular high schools and tertiary education institutions must be led by the Chinese 

party, i.e., the principal or main administrator must be a Chinese national and be 

domiciled in China; the board of the school must have a Chinese majority and the 

education program must be in line with Chinese law.

Health and social work

Medical institutions can be set up as equity or contractual joint ventures.
132

Science and technology

Most types of mapping activities are prohibited for political reasons.

1. Mapping of the oceans, administrative boundaries, political maps, maps for use in 

education, aerial photography, most other types of maps, and geological research: 

Prohibited.

2. For companies engaging in mapping that is allowed: Requires Chinese controlling 

interest.

3. Human stem cell and genetic research: Prohibited.

4. Establishing and operating social science research centers: Prohibited.

Media, culture, and entertainment

1. The establishment and operation of television and radio stations, television channels, 

broadcast networks, satellite television, TV on-demand, and other broadcast media: 

Prohibited.

2. The production of television and radio shows: Prohibited.

3. Foreign satellite channels are subject to approval.

4. Sino-foreign co-productions of television and film series are subject to a licensing 

system.

5. The establishment of news and press agencies, publishing companies, and newspapers: 

Prohibited.

6. Foreign news agencies may set up a representative office in China and employ foreign 

reporters upon approval of the Chinese government. Foreign press agencies may provide 

news services in China upon approval of the Chinese government.

7. The production of newspapers, books, audiovisual materials, periodicals, electronic 

publications, etc.: Prohibited.

8. Cooperation between Chinese and foreign news agencies must be led by the Chinese side 

and is subject to approval of the Chinese government.

9. Provision of financial information is subject to approval of the Chinese government.

10. The construction and operation of cinemas: Prohibited.

11. The establishment of performing arts groups in China is prohibited, and performance 

agencies must have Chinese controlling interest.

The new negative list no longer prohibits construction of villas, nor does it restrict investment in 

hotels, offices, and convention centers.

Foreign Investment National Security Review

The new free trade zone regulations state that certain foreign investments will be subject to a 

National Security Review. The concept of a National Security Review was first introduced when 

the Chinese government released a draft of the new Foreign Investment Law. The intention 

behind the National Security Review is to keep national security risks in check while more 

industries are opened to foreign investment.
133

The review is conducted by the National Development and Reform Commission and the 

Ministry of Commerce, usually at the suggestion of the registration authority of the FTZ. Such a 

review considers six factors:

1. Impact on national security, including China’s capacity to provide essential goods and 

services to that end.

2. Impact on the stability of the economy.

3. Impact on basic social order.

4. Impact on culture and social morality.

5. Impact on Internet security.

6. Impact on sensitive technology for use in national defense.

The review is held when an investment is believed to touch upon sensitive agricultural products, 

key natural resources and energy, strategic infrastructure, transport capabilities, important IT and 

technology, or investment near military facilities.

Interestingly, the review does not merely look at the equity a foreign party has in a Chinese 

company, but extends to the “actual control” over a company. In the separate regulation that 

introduces this National Security Review, the term “actual control” is defined for the first time. It 

refers to one or more foreign investors, and parties affiliated to them (i) holding over 50 percent 

of a company’s shares; (ii) having sufficient voting rights to exert significant control over the 

company’s board of directors or shareholder’s meeting; or (iii) through other circumstances, 

being able to exert significant control over the company’s operational decision, staffing, finance,

or technology.

Also, the regulation does not only apply to foreign entities setting up a company in China or 

purchasing the shares or assets of Chinese companies. “Foreign investment” is also considered to 

be obtaining control by agreement, holding of assets by an agent for a foreign entity, transactions 

that 
134

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