Q&A on the Circular of the State Administration of Foreign Exchange on Further Promoting the Facilitation of Cross-border Trade and Investment Question 1: How will the pilot policy on facilitation of trade foreign exchange receipts and payments be implemented? A: Article 1 of the Circular of the State Administration of Foreign Exchange on Further Promoting the Facilitation of Cross-border Trade and Investment (Huifa [2019] No. 28, hereinafter referred to as the Circular), "Expanding the Pilot Scheme for Facilitation of Foreign Exchange Receipts and Payments for Trade" refers to expanding the scope of regions and business scope of the pilot scheme for facilitation of foreign exchange receipts and payments for trade, on the basis of the pilot schemes of the Guangdong, Hong Kong, Macau and the Greater Bay Area, as well as those of Shanghai and Zhejiang in the previous period.  In the same way as the previous pilot, this expansion of the pilot policy will be formulated by each pilot branch according to the actual needs of the location of the pilot program, and the conditions, procedures and management requirements of the pilot will be announced to the public, and eligible banks may file the pilot with the Foreign Exchange Bureau and carry out the relevant pilot business in accordance with the regulations. Question 2: How do banks and payment institutions grasp the requirement that the cumulative amount of annual goods trade receipts or remittances of small and micro cross-border e-commerce enterprises is less than USD 200,000 in Article 5 of the Circular? A: Payment institutions or banks, in accordance with the Notice of the State Administration of Foreign Exchange on the Issuance of <Methods for the Administration of Foreign Exchange Business of Payment Institutions> (Huifa 〔2019〕 No. 13), can grasp the following principles when handling foreign exchange receipts and payments of trade in goods for micro and small cross-border e-commerce enterprises: first, through the payment institutions' or banks' own electronic business systems to monitor the cross-border e-commerce enterprises' trade in goods handled by the institution during the year First, through the payment institutions or the bank's own electronic business system to monitor the collection or payment of foreign exchange for trade in goods handled by the enterprise during the year, the small and micro cross-border e-commerce enterprises with the cumulative amount of collection or payment of foreign exchange for trade in goods of less than 200,000 US dollars in the year may not be required to apply for the directory of "trade foreign exchange receipts and payments enterprises". Secondly, the Foreign Exchange Bureau will notify payment institutions and banks on a monthly basis of the list of non-listed enterprises whose cumulative amount of foreign exchange receipts or payments for trade in goods exceeds the equivalent of USD 200,000 in a year. Payment institutions and banks can check the above list with their own list of corporate clients and remind corporate clients engaged in cross-border e-commerce of trade in goods to apply for the "Trade Foreign Exchange Receipts and Payments Enterprise" directory within one month from the date of publication of the list. enterprises" list within one month from the date of publication of the list. In the future, payment institutions and banks can network with the Foreign Exchange Bureau through interfaces and other means to realize the automatic transmission of the list of non-listed enterprises through the system. Question 3: Article 8 of the Circular stipulates that enterprises shall realize online processing of trade credit, trade financing and other business reports, which business reports are specifically referred to? A: According to the Circular of the State Administration of Foreign Exchange on Issues Relating to the Issuance of Regulations on Foreign Exchange Management of Trade in Goods (Huifa [2012] No. 38, hereinafter referred to as Circular No. 38), for "trade credit business", "trade financing business", For "trade credit business", "trade financing business", "re-export trade receipts and payments business", "difference business" and "other special transaction business", enterprises shall fulfill their reporting obligations in accordance with the regulations if they meet the reporting conditions. Since January 1, 2020, regardless of whether the interval between the date of occurrence of business and the actual reporting date is more than 30 days, the above business reports can be processed online through the Foreign Exchange Monitoring System for Trade in Goods. The statutory reporting time limit for the above business reports is still in accordance with Circular 38, e.g., for deferred payment business of more than 90 days (not included), enterprises shall report the expected payment information within 30 days from the date of importation of goods. Question 4: After Article 9 of the Circular relaxes the opening of the account for verification of export income, are the revenues from offshore resale and remittance of Class A enterprises and the revenues from trade in goods of Class B/C enterprises still required to be entered into the account for verification of export income? A: Article 9 of the Circular has made it clear that enterprises handling income from trade in goods may independently decide whether or not to open an account for export income pending verification. This article applies to the income from offshore resale and remittance of enterprises whose goods trade classification result is Class A, as well as the income from goods trade of Class B/C enterprises. Banks are required to conduct due diligence audits on the authenticity, compliance and reasonableness of the above businesses in accordance with the current regulations. Question 5: Is the signature of the legal representative of the enterprise required in the "Application for Registration on the List of Foreign Exchange Receipts and Expenditures Enterprises for Trade in Goods" and "Confirmation of Handling of Foreign Exchange Receipts and Expenditures for Trade in Goods" (hereinafter referred to as the relevant materials) submitted by enterprise branches for the registration on the "Foreign Exchange Receipts and Expenditures Enterprises for Trade in Goods" list? A: When a branch of an enterprise applies for registration in the "Foreign Exchange Receipts and Payments of Trade in Goods Enterprises" list in accordance with Article 10 of the Circular, the relevant materials can be signed by the legal representative of the enterprise, or the signature of the person in charge of the branch as set out in the "Business License".