Cross-Border Capital Flow Management: The Art of Balancing

Recently, the China Securities Regulatory Commission (CSRC) introduced a new plan to rectify problems in cross-border securities, futures, and fund business activities. With the support of the Securities and Futures Commission of Hong Kong and the Hong Kong Monetary Authority, the rules governing the opening of securities investment accounts in Hong Kong by Mainland clients…


Professor Xiang Fang

24 June 2026

Recently, the China Securities Regulatory Commission (CSRC) introduced a new plan to rectify problems in cross-border securities, futures, and fund business activities. With the support of the Securities and Futures Commission of Hong Kong and the Hong Kong Monetary Authority, the rules governing the opening of securities investment accounts in Hong Kong by Mainland clients were also updated simultaneously.

Under the regulatory rectification plan, illegal cross-border business activities by overseas securities, futures, and fund institutions will be completely banned within two years. Existing clients may sell but may not buy, and all Mainland websites, trading software, and ancillary services will be shut down. Meanwhile, Futu Securities, Tiger Brokers, and Long Bridge Securities have been severely penalized for engaging in illegal cross-border business solicitation and activities.

Strict enforcement of existing laws and regulations

The rectification plan may be described as a forceful crackdown targeting cross-border investment in securities, futures, and funds. Under existing laws and regulations, Mainland residents are subject to an annual aggregate quota of US$50,000 per person for foreign-exchange settlement and purchase, which may be used only for purposes such as overseas travel and study, and not for overseas property purchases, overseas investment, life insurance or similar purposes. Strictly speaking, Mainland residents may not use foreign exchange converted from domestic funds to engage in overseas securities investment. This is also the basis on which institutions require account-opening applicants to demonstrate that their funds come from legitimate overseas sources.

In practice, brokerages may not always be fully rigorous in verifying users’ sources of funds. Some brokerages also circumvent existing regulations by various means, entering the Mainland market to advertise, solicit clients, and provide trading facilities and services. The above-mentioned brokerages that were heavily penalized fall into this category. Therefore, the rectification plan is not a new regulation on overseas investment by Mainland residents, but rather the strict enforcement of existing laws and regulations.

China has long maintained a cautious stance towards capital account convertibility. The current framework for managing capital flows mainly comprises two mechanisms. First, China has established the Qualified Foreign Institutional Investor (QFII) mechanism for investment in Mainland securities by qualified foreign institutional investors, and the Qualified Domestic Institutional Investor (QDII) mechanism for investment in overseas securities by qualified domestic institutional investors, allowing relevant institutions to conduct cross-border capital flows and transactions. Both are subject to quota management. Second, China has established multiple cross-border mutual market-access channels, such as the Shanghai-Hong Kong Stock Connect, the Shenzhen-Hong Kong Stock Connect, and Bond Connect, through which investors can legally invest in specified overseas assets.

Potential benefits of moderate capital account management

In international academia and public policy circles, views on the free movement of capital have changed significantly over the past several decades. In the 1990s, the mainstream view was that late-developing countries should promote the full liberalization of the capital account in order to achieve efficient cross-border allocation of capital. As this idea gained wide acceptance, cross-border capital flows grew rapidly. However, in the years that followed, many countries that advanced capital account liberalization, for example, Mexico, Turkey, and South Korea, experienced financial crises of varying severity. In some countries, crises were triggered by the withdrawal of foreign capital. In others, although the crises originated domestically, the sudden withdrawal of foreign capital further exacerbated them. The mainstream view accordingly reversed.

By 2012, the International Monetary Fund acknowledged in its documents that full capital account liberalization might not be suitable for late-developing countries. The academic community has since conducted extensive research on this issue, examining whether capital account management policies are appropriate as a macroprudential tool and offering recommendations on how to implement optimal macroprudential capital account management. According to my recent research with Professor Yang Liu of the University of Hong Kong, Professor Sining Liu of Soochow University, capital account management is conducive to lowering exchange-rate risk in late-developing countries, thereby reducing local-currency financing costs.

The art of balancing financial openness and stability

The main threat posed by the free movement of capital to an economy comes from sudden disruptions in capital inflows, including large-scale outflows of domestic capital and the withdrawal of foreign capital. If these occur within a short period of time, they will seriously affect the stability of domestic financial markets. To prevent the sudden withdrawal of foreign capital, a starting point can be to limit large-scale inflows of foreign capital. Managing capital inflows in a macroprudential manner can help mitigate potential capital outflows. This helps to explain the Chinese authorities’ concern about large inflows of foreign capital: if foreign capital is rapidly withdrawn as a result of changes in risk appetite, confidence, or other factors, it will trigger sharp fluctuations in domestic financial markets.

China has steadily and prudently promoted financial openness over the past dozen years. In particular, over the last five or six years, compliant funds for domestic investment in overseas securities have grown by as much as threefold, and the trend of China’s gradual financial opening remains unchanged. At the same time, China’s regulatory focus on capital and financial account transactions that have not yet been fully liberalized stems from its concern that rapid capital withdrawal could endanger domestic financial stability. From the perspective of macroprudential regulation, regulators may consider further refining the management of foreign capital. Research by Professor Haonan Zhou of the University of Hong Kong indicates that, in terms of the stability of funding sources, not all international capital should be treated alike. Long-term capital, such as insurance funds, pension funds, and bank funds, tends to exhibit relatively stable investment behaviour and is less affected by international financial turbulence. Short-term capital, such as mutual funds and hedge funds, is more susceptible to financial market volatility. Therefore, in order to manage capital flows with greater precision, regulators should conduct tiered monitoring and management based on the nature of different types of capital and their respective sensitivity to international and domestic financial factors.

Prudent policymaking requires adapting to circumstances

It is worth noting that concern over funding disruptions caused by large-scale capital outflows is another logical basis for the Chinese authorities’ cautious approach to capital outflows. Domestic capital is formed within China and can be managed only by regulating capital outflows. The recent rectification plan targeting overseas securities investment activities is also mainly driven by this rationale. At the same time, regulators must recognize that, against the backdrop of increasing uncertainty in the international environment, many investors have genuine demand for cross-border investment for purposes such as sharing in investment returns and diversifying risks. In the medium to long term, the appropriate response should favour guidance over obstruction, with a focus on maintaining a balance between controlling financial risks and meeting cross-border investment needs.

In fact, while rectifying grey-area cross-border securities trading, regulators may also consider correspondingly expanding the scope of lawful cross-border securities investment. For example, they could lower the thresholds for QFII and QDII quotas and expand the coverage of various mutual market-access mechanisms, so that investors can make up for losses in one area with gains in another, thereby further advancing gradual financial opening-up. As with the management of foreign capital, in promoting policies to prudently broaden lawful channels for cross-border securities investment, the authorities should focus on designing effective mechanisms to screen for relatively stable funds, so as to facilitate the sharing of global investment returns and meet the need for risk diversification.

Translation

跨境資本流動管理的平衡藝術

近期,中國證券監督管理委員會出台新方案,以整治跨境證券期貨基金經營活動,並得到香港證券及期貨事務監察委員會和金融管理局支持,同步更新內地客戶赴港開設證券投資帳戶的規則。

根據整治方案,境外證券期貨基金經營機構的非法跨境經營活動,將在兩年內被全面取締,現有客戶只可賣出不能買入,境內網站、交易軟件及配套服務都將全面關停。同時,富途證券、老虎證券和長橋證券因涉非法跨境展業行為遭到嚴厲懲罰。

嚴格執行現行法律法規

這一整治方案堪稱針對跨境證券期貨基金投資的重拳。根據現有法規,內地居民每人年度結匯購匯總額為5萬美元,用途僅限於境外旅遊、留學等,不得用於境外買房、境外投資、人壽保險等項目。嚴格來講,在境外從事證券投資,內地居民不能使用境內資金所兌換的外匯,此亦為機構要求開戶者出示資金來自境外合法來源的理據。

在實際操作中,券商在核查用戶收入來源時,未必做到絕對嚴謹,亦有券商通過種種手段規避現有監管,進入境內進行廣告招徠、提供交易便利與服務,上述遭到重罰的幾家券商即屬此列。因此,此整治方案並非內地居民對外投資的新規定,而是嚴格執行現行法律法規。

長期以來,中國對自由兌換資本的立場始終保持審慎。當前的資本流動管理框架主要包括以下兩個機制。一、建立了合格境外機構投資者(Qualified Foreign Institutional Investor;簡稱QFII)投資內地證券,以及合格境內機構投資者(Qualified Domestic Institutional Investor;簡稱QDII)投資境外證券的機制,允許相關機構進行跨境資本流動交易;兩者均採用配額管理。二、設立多個跨境互聯互通途徑,如滬港通、深港通、債券通等,投資者得以合法投資境外特定資產。

適度資本帳戶管理或有裨益

在國際學術界與公共政策界,對資本自由流動的認知,在過去數十年間發生了重要變化。1990年代,主流觀點認為後發國家應推動資本項目完全開放,實現資本跨國有效配置。隨着這一理念深入人心,跨國資本流動迅速增加。然而,接下來數年間,許多推進資本帳戶自由化的國家(如墨西哥、土耳其、韓國)均遭遇不同程度的金融危機。部分國家的危機由外資撤離引爆;另有部分國家雖禍起於蕭牆之內,但外資突然撤離更使危機雪上加霜。這一主流思潮也隨之逆轉。

及至2012年,國際貨幣基金組織在其文件中承認,完全資本帳戶自由化對後發國家未必適用。學術界為此展開了大量研究工作,論證作為宏觀審慎性工具之一的資本帳戶管理政策是否適切,並對如何施行最優的宏觀審慎資本帳戶管理提出建議。根據筆者與香港大學劉洋教授、蘇州大學劉思寧教授的近期研究,資本帳戶管理可以降低後發國家的匯率風險,從而降低本幣融資成本。

金融開放與穩定的平衡藝術

資本自由流動對一個經濟體的主要威脅來自資金突然中斷,包括國內資本大量外流,以及外國資本撤退,若在短時間內發生,必將嚴重影響國內金融市場的穩定性。為防外國資本突然撤離,可從限制外資大量進入著手。以宏觀審慎的方式管理資本流入,就能穩定資本可能流出。由此可以理解中國當局對大量外資湧入的顧慮——如果外資因風險偏好、信心等因素發生變化而急速撤出,必將引觸發國內金融市場劇烈波動。

中國十數年來穩慎推動金融開放。尤其是最近五六年間,國內投資境外證券的合規資金大幅增長達三倍之多,中國漸進式推進金融開放的趨勢仍不可更易。與此同時,中國將監管重點放在尚未完全開放的資本與金融項目,源於其對資金快速撤離危及國內金融穩定的憂慮。從宏觀審慎監管的角度出發,監管部門可考慮進一步對外資加以精細化管理。香港大學周皓南教授的研究指出,以資金來源的穩定性而言,並非所有國際資本都可等量齊觀。長期資本如保險資金、養老金、銀行資金等,其投資行為相對穩定,受國際金融動盪的影響也較低。至於共同基金、對沖基金等短期資本,則較易受到金融市場動盪的衝擊。因此,監管機構為求對資本流動加以精細化管理,理應根據各類資本的性質及其對國際、國內金融因素的不同敏感度,以進行分層跟蹤與管理。

審慎決策有賴因勢利導

值得注意的是,因資本大量外流而造成對資金中斷的顧慮,正是當局為何對資本外流十分審慎的另一邏輯基礎。國內資本形成於中國境內,只能通過調節資本外流來進行管理;近期對境外證券投資行為的整治方案也主要出於這一動機。與此同時,監管者必須正視在國際環境不確定性加劇的大前提下,不少投資者出於收益分享、風險分散等目的,而對跨境投資具有客觀需求,中長期的應對策略是宜疏不宜堵,並聚焦於管控金融風險和滿足跨境投資之間維持平衡。

事實上,在整治灰色跨境證券交易的同時,監管機構不妨考慮相應地擴大合法跨境證券投資的範圍,例如降低QFII 、QDII的額度,擴大各互聯互通機制的覆蓋面,讓投資者能夠失之東隅,收之桑榆,進一步擴大漸進式金融開放。與管理外資類似,在審慎擴大合法跨境證券投資渠道的政策推進中,當局應著力於設計有效機制,從而篩選出相對穩健的資金,以促進全球投資收益分享和風險分散需求。

方翔教授
港大經管學院金融學助理教授

(本文同時於二零二六年六月二十四日載於《信報》「龍虎山下」專欄)