关键词: 反洗钱; 金融行动特别工作组; 特定非金融机构; 制度移植; 合规

Abstract: Given the international consensus on strengthening anti-money laundering (AML) regulation， how to make up for the shortcomings of China's DNFBPs' AML regulation has become an urgent issue to be resolved. As an atypical institutional transplantation， the construction of a DNFBPs' regulatory system based on the international consensus standards is not compatible with China's socio-economic development. It is difficult to match the existing AML structure with the financial regulatory orientation， nor does it eliminate the conflict with the basic professional ethics of a particular industry， and it lacks systemic support from the general rules of conduct on access to information. In the process of mitigating the rejection of institutional transplantation， it is necessary to reveal how macro policy focus and governance model transformation can provide incentives for innovating the DNFBPs' AML regulatory system from a bidirectional perspective. In turn， based on a functional and scenario-based approach and a risk-based approach， an intelligence-focused collaboration mechanism will be built， a scenario-based disclosure standard will be reshaped and a risk-based compliance system will be promoted. Ultimately， the local adaptation of DNFBPs' AML regulation based on practical constraints will be realized.

Key words: anti-money laundering(AML); financial action task force(FATF); designated non-financial businesses and professions(DNFBPs); institutional transplantation; compliance