This service is a core module of China Compliance Risk Review™, designed to support the overall compliance infrastructure for China operations.
In China, payment risk rarely arises from incorrect payments — it arises when no one can clearly explain how a payment was authorized.
For many foreign-invested enterprises, the primary objective of banking setup is functionality: receiving funds, making payments, and processing expenses.
In practice, however, payment risks often stem from:
Convenience-driven permission settings
Disconnection between approvals and business substance
Misalignment between bank operations and internal authorization
Limited HQ visibility into payment processes
The Banking & Payment Control Setup focuses not on opening accounts, but on structural control, explainability, and traceability of funds.
Why “Being Able to Pay” Is Not the Same as Being in Control
Common high-risk situations include:
One individual controlling both approval and execution
Lack of segregation in online banking permissions
Payments supported only by invoices or informal explanations
HQ unable to distinguish authorized vs. discretionary payments
Such issues may remain hidden in daily operations, but quickly escalate during audits, tax reviews, or internal assessments.
Key Areas We Assess
1 | Banking Permissions and Role Segregation
Whether approval, execution, and review are segregated
Whether end-to-end control rests with a single individual
Whether bank permissions align with governance roles
2 | Linkage Between Payments and Business Substance
Whether payments are directly tied to contracts and activities
Whether approvals consider amount, nature, and risk level
Whether approvals are substantive rather than procedural
3 | Alignment Between Bank Operations and Internal Authority
Whether internal authorization is reflected in bank controls
Whether bank-side permissions are transparent to HQ
Whether gaps exist between policy and practice
4 | Traceability and Explainability of Payments
Whether payment decisions can be reconstructed retrospectively
Whether approvals, rationale, and documentation are traceable
Whether records support HQ or audit-level understanding
Common but Overlooked Risk Scenarios
Centralizing online banking access for efficiency
Informal approvals via messaging without records
Inconsistent approval standards for similar payments
Staff turnover leaving payment logic unexplained
The issue is not the payment itself — it is the loss of explainability.
What This Module Is Not
This module does not include:
Bank account opening services
Execution of payments or approval delegation
Internal control system implementation
Outcome guarantees
It is a governance- and explainability-focused design module, not an execution service.
What You Will Receive
Risk assessment of banking and payment controls
Identification of concentrated permission risks
Evaluation of payment explainability for HQ
A governance-oriented control design framework
Position Within China Entry + Governance Package
This module:
Follows governance and authorization design
Supports seal, contract, and expense control
Directly enhances HQ visibility and risk management
In China, payment risk lies not in the amount paid, but in whether the payment can be clearly explained.
We do not make decisions for you; we only help you clarify facts and risks.
Phone : 400 800 7472
Email : info@rtfcpa.com
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