To all market participants:
Recently, during relevant business inspections and self-regulatory investigations, the National Association of Financial Market Institutional Investors (NAFMII) has discovered that some institutions lack internal controls, have compliance and risk management that is merely superficial, and the issue of failing to preserve bond trading records as required is quite prevalent. These problems severely hinder the reconstruction of transaction facts and are detrimental to effective supervision and the crackdown on illegal activities. In response to the aforementioned situations, NAFMII will increase the severity of penalties for related violations. Institutions found to have the following issues will face stricter and heavier sanctions, with corresponding self-regulatory disciplinary actions imposed based on the severity of the specific violation, including:
1. Failure to establish and健全 sound internal control systems related to bond trading record preservation as required; 2. Compliance and risk management being merely formalities, failing to effectively implement internal control systems for bond trading record preservation; 3. Bond trading records not being fully traceable throughout the process as stipulated; 4. Inability to provide complete trading records to reconstruct the facts of transactions suspected of serious violations; 5. Other behaviors that violate relevant requirements for bond trading record preservation.
Establishing robust internal controls and preserving trading records completely, accurately, and comprehensively as required are fundamental institutional requirements of the bond market and a crucial obligation for all market participants. All market participants must attach great importance to this matter and effectively enhance their compliance awareness and performance levels. NAFMII will continue to strengthen related management to promote the healthy and orderly development of the market.
This notice is hereby issued.
National Association of Financial Market Institutional Investors January 4, 2026
