NFRA Data Security Measures–Implications for Foreign Funded Bank

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Authors: Han Kun Law Offices Ting Zheng丨Raymond Yan 丨Eryin Ying丨Lin Zhu丨Shirley Liang丨Hattie Zhang The National Financial Regulatory Administration (" NFRA ") released the Measures for Data Security Management of Banking and Insurance Institutions (《银行保险机构数据安全管理办法》)(" Data Security Measures ") on 27 December 2024, which came into effect immediately upon promulgation. Prior to that, NFRA circulated the first draft among banks on 5 September 2023 and the second draft to solicit public comments on 22 March 2024 (" Draft Measures "). The Data Security Measures substantially stay the same as the Draft Measures, with only minor wording changes and non-substantial additions. We set out below the key requirements under the Data Security Measures and potential implications for foreign funded banks (including subsidiary banks and where applicable, foreign bank branches) (" Banks " or a " Bank ") in China. If you require a PDF copy of this summary note, ………………………………