——中国银行管控的系统性不对称
作者：周敏
编辑：胡丽莉 校对：王滨 翻译：戈冰
银行，在世人常识中是储户资金最安全的去处。存入，取出，天经地义。但是你发现没有？近年来，一个奇异的景象在中国银行体系中反复上演：骗子和内部人员能以惊人的效率将储户的钱转走，而储户自己要取回这笔钱，却要面对预约、盘问、证明、审查，乃至被拒之门外。
而这番景象，究根结底，是1949年后中国一切为党服务的制度设计之必然结果。
一、两个场景，两种速度
2025年10月，吉林省扶余市。储户陈冰将1000万元企业备用金存入扶余惠民村镇银行，业务由该行员工赵某丽经办。同月，另一储户王女士也将800万元积蓄存入同一银行，同样由赵某丽负责。赵某丽此前以完成存款指标为由，向储户承诺高于公开利率的回报，多次准时兑付，储户逐渐放松警惕。
2025年12月，陈冰发现手机银行无法登录，前往营业厅查询，被告知银行卡已挂失，账户内仅余一万余元——1000万元几近转空。王女士的800万元同样不翼而飞，银行拒绝提供资金流水凭证，隐瞒资金去向。事后查明，赵某丽通过伪造签名、冒名挂失补办银行卡等手段，将两人合计1800万元非法转走。赵某丽事发后服药轻生，被救回后已被批捕。
两笔共计1800万元的资金，从存入到被转空，整个过程银行系统没有触发任何有效预警，没有任何人主动通知储户。
现在再把镜头切换到另一个场景。
2024年，邢台，一名女子因丈夫病重急需现金支付医疗费用，前往银行取款。她被柜员以”大额取现”为由长时间盘查，反复追问资金用途，取款受阻。同年，沈阳一女子欲取5000元，被要求其丈夫必须到场。青岛一男子因无法当场提供”资金来源证明”，无法取出自己账户里的钱。吉林省某银行更一度要求取款超过2万元，须持辖区派出所出具的证明。
同一金融系统，同类账户里的钱。内部人员转走1800万，无声无息；储户自己取几万，困难重重。
二、管控的方向
要理解这种不对称，就得先理解这套管控机制究竟是为谁设计的。
中国银行体系在名义上服务储户，在结构上却是向上负责——对党政体系、监管机构、中共维稳负责。储户在法律意义上对银行拥有债权，而非对自己资金的直接所有权。这个区别在正常时期几乎感知不到，在危机时刻则暴露无遗。
大额现金管理制度要求5万元以上取现须提前预约，取款时须说明用途。这套机制的官方理由是反洗钱和反电信诈骗，但其实际功能远不止于此：这是让国家实时掌握大额资金流向，防范资本外逃，监控政治敏感资金异动。换言之，它首先是一套资本管控工具，其次才是反诈工具，保护储户则排在更后面。
柜员层面还存在一个自我加强的机制：若柜员放行了一笔事后被认定为涉诈的资金，将被个人处罚扣薪。这意味着柜员的理性选择必然是尽可能设置障碍，因为柜员清楚地看到，误伤普通储户的代价，远远低于放行涉诈资金的代价。于是每一个急需用钱的病人家属，每一个临时周转的商户，都成了这套风控机制的潜在嫌疑人。
与此形成鲜明对比的是，内部人员作案时走的则是监控之外的路径。系统级权限、职务便利、伪造票证——这些手段绕过柜台风控流程与前端审查。看见了吗？监控最严密的地方，恰恰是普通人取自己钱的窗口；漏洞最多的地方，恰恰是内部人员施展空间的后台。
三、爆雷之后的维权困境
内部人员作案尚属个案，但是，当机构本身成为掠夺者，这套不对称就会以更大的规模呈现。
2022年，河南四家村镇银行毫无预警地同时关闭线上取款渠道，约40万储户发现自己的存款无法提取。事后查明，银行股东以河南新财富集团为核心，通过内外勾结，将储户资金系统性转移，涉案金额据估计逾百亿元人民币。在这里，作恶的是谁？正是银行本身。
储户前往郑州维权，健康码被莫名赋红，无法进入郑州。大规模抗议现场出现身份不明的白衣人强行驱散人群，部分储户遭到殴打。随后，当局以”先垫付5万元以下”的方式分化维权队伍——拿到钱的人不再闹，剩下大额储户人数越来越少，声音越来越小。时至今日，仍有逾千名储户未获任何赔偿。
这套处置方式表明了一件事：当储户利益与维稳目标发生冲突，优先被保护的并不是储户利益。
四、制度性不对称的本质
上述案例放在一起通盘观察，可以看见一个清晰的脉络：
这套系统对资金流动的管控方向是倒置的。它对内部人员盗转、股东掏空几乎无效，对普通储户取回自己的钱反倒层层设防、令人崩溃。反洗钱反电诈的说法，为机构失职提供了合规掩护，同时还把监控资本流动的成本，以审查程序的名义转嫁给了储户。
工行南宁分行原高管梁建红，以伪造存单、替换票证的方式，历时数月转走11名储户约2.5亿元存款，银行系统全程未能有效识别。判决后，银行的第一个动作就是把责任归咎于员工个人行为；储户的民事赔偿诉求则被要求”先刑后民”，等待刑事追赃程序走完——而那个程序，可以漫长得以年来计算。
当储户被要求向银行证明自己有权取回自己的钱，这个关系已经不是存款关系，而是实质上的管控关系。银行不是服务方，而是施压方、管理方、控制方。
在一个法治健全的金融体系里，举证责任天然地落在银行一侧：银行须证明有法定理由才能拒绝支付。而在今天的中国，这个举证责任已经悄然倒置。储户不再是委托人，而更像是需要持续自证清白的被审查者。
面对这样的结构，储户究竟还能做什么来保护自己？这个问题，恐怕没有在现行体制内寻找答案的空间。
The People’s Money, the Party’s Decision
—Systemic Asymmetry in China’s Banking Oversight
Author: Zhou Min
Editor: Hu Lili Proofreader: Wang Bin Translator: Ge Bing
Abstract: In many regions, banks have failed to issue timely warnings when internal staff embezzle funds, while depositors face strict scrutiny and restrictions when attempting to withdraw their money. This article highlights the asymmetry within the financial system regarding the treatment of ordinary depositors versus internal risk management.
In the common understanding, banks are the safest place for depositors’ funds. Depositing and withdrawing money is a matter of course. But have you noticed? In recent years, a bizarre phenomenon has repeatedly unfolded within China’s banking system: fraudsters and insiders can transfer depositors’ money away with astonishing efficiency, while depositors themselves face appointments, interrogations, proof requirements, and scrutiny—and are even turned away—when trying to retrieve their own funds.
Ultimately, this phenomenon is the inevitable result of China’s post-1949 institutional design, which prioritizes serving the Party above all else.
I. Two Scenarios, Two Speeds
October 2025, Fuyu City, Jilin Province. Depositor Chen Bing deposited 10 million yuan in corporate contingency funds into Fuyu Huimin Rural Commercial Bank, with the transaction handled by bank employee Zhao Mouli. That same month, another depositor, Ms. Wang, also deposited 8 million yuan in savings into the same bank, again under Zhao Mouli’s supervision. Zhao Mouli had previously promised depositors returns higher than the published interest rates, citing the need to meet deposit quotas, and made timely payments on multiple occasions, causing the depositors to gradually let down their guard.
In December 2025, Chen Bing discovered he could not log into the mobile banking app. Upon visiting the branch to inquire, he was informed that his bank card had been reported lost, and only about 10,000 yuan remained in his account—the 10 million yuan had nearly vanished. Ms. Wang’s 8 million yuan had also disappeared without a trace, and the bank refused to provide transaction records, concealing the funds’ whereabouts. Subsequent investigations revealed that Zhao Mouli had illegally transferred a total of 18 million yuan from the two women by forging signatures and fraudulently reporting their cards lost to obtain replacements. After the incident, Zhao attempted suicide by overdosing on medication; she was rescued and has since been arrested.
Throughout the entire process—from the deposit of the two sums totaling 18 million yuan to their complete depletion—the bank’s system failed to trigger any effective alerts, and no one proactively notified the depositors.
Now let’s shift our focus to another scenario.
In 2024, in Xingtai, a woman went to a bank to withdraw cash urgently needed to cover her husband’s medical expenses. She was subjected to a lengthy interrogation by a teller on the grounds of a “large cash withdrawal,” repeatedly questioned about the funds’ intended use, and ultimately prevented from withdrawing the money. That same year, in Shenyang, a woman attempting to withdraw 5,000 yuan was told her husband must be present. In Qingdao, a man was unable to withdraw money from his own account because he could not provide “proof of funds” on the spot. A bank in Jilin Province even went so far as to require a certificate issued by the local police station for withdrawals exceeding 20,000 yuan.
The same financial system, money in similar accounts. When an insider transfers 18 million yuan, it goes unnoticed; when a depositor tries to withdraw a few tens of thousands, they face immense difficulties.
II. The Direction of Control
To understand this asymmetry, one must first understand for whom this control mechanism was actually designed.
China’s banking system nominally serves depositors, but structurally, it is accountable upward—to the Party and government system, regulatory bodies, and the CCP’s stability maintenance apparatus. Legally speaking, depositors hold claims against the bank, rather than direct ownership of their funds. This distinction is barely perceptible in normal times but becomes glaringly obvious in times of crisis.
The large-cash management system requires advance reservations for cash withdrawals exceeding 50,000 yuan, with the purpose of the withdrawal to be stated at the time of withdrawal. The official justification for this mechanism is anti-money laundering and anti-telecom fraud, but its actual functions go far beyond that: it allows the state to track the flow of large sums of money in real time, prevent capital flight, and monitor politically sensitive financial movements. In other words, it is first and foremost a tool for capital control, secondarily an anti-fraud tool, with the protection of depositors ranking even lower on the list of priorities.
At the teller level, there is a self-reinforcing mechanism: if a teller approves a transaction that is later identified as fraud-related, they face personal penalties, including salary deductions. This means that the rational choice for a teller is inevitably to create as many obstacles as possible, because they clearly see that the cost of mistakenly inconveniencing ordinary depositors is far lower than the cost of allowing fraud-related funds to pass through. Consequently, every family member of a patient in urgent need of funds and every merchant seeking temporary liquidity becomes a potential suspect under this risk control mechanism.
In stark contrast, when internal personnel commit fraud, they take paths outside the scope of surveillance. System-level permissions, the convenience of their positions, and forged documents—these methods bypass counter-level risk control processes and front-end reviews. Do you see? The most heavily monitored areas are precisely the windows where ordinary people withdraw their own money; the areas with the most vulnerabilities are precisely the back offices where internal personnel have room to operate.
III. The Dilemma of Seeking Redress After a Financial Scandal
While insider fraud is typically an isolated incident, when the institution itself becomes the predator, this asymmetry manifests on a much larger scale.
In 2022, four village banks in Henan simultaneously shut down their online withdrawal channels without warning, leaving approximately 400,000 depositors unable to access their funds. Subsequent investigations revealed that bank shareholders, led by the Henan New Fortune Group, had systematically diverted depositors’ funds through collusion with both internal and external parties, with the total amount involved estimated to exceed 10 billion yuan. Who was responsible for this wrongdoing? It was the banks themselves.
When depositors traveled to Zhengzhou to demand their rights, their health codes were inexplicably marked red, preventing them from entering the city. At the site of large-scale protests, unidentified individuals in white clothing forcibly dispersed the crowd, and some depositors were beaten. Subsequently, the authorities sought to divide the protest group by offering “advance payments of up to 50,000 yuan”—those who received the money stopped protesting, while the number of depositors with larger balances dwindled, and their voices grew fainter. To this day, over a thousand depositors have yet to receive any compensation.
This approach reveals one thing: when the interests of depositors conflict with the goal of maintaining social stability, it is not the depositors’ interests that are prioritized.
IV. The Essence of Institutional Asymmetry
When viewed holistically, the cases described above reveal a clear pattern:
This system’s approach to controlling capital flows is inverted. It is virtually ineffective against embezzlement by insiders or asset stripping by shareholders, yet it erects layer upon layer of barriers—often to the point of frustration—to prevent ordinary depositors from retrieving their own money. The rhetoric of anti-money laundering and anti-telecom fraud provides a compliance cover for institutional dereliction of duty, while simultaneously shifting the cost of monitoring capital flows onto depositors under the guise of review procedures.
Liang Jianhong, a former senior executive at the Nanning Branch of the Industrial and Commercial Bank of China (ICBC), embezzled approximately 250 million yuan in deposits from 11 depositors over several months by forging deposit certificates and swapping physical documents—a scheme the banking system failed to detect throughout the entire process. Following the verdict, the bank’s first move was to attribute the blame to the employee’s individual actions; meanwhile, depositors’ civil compensation claims were met with the requirement to “pursue civil claims after criminal proceedings,” forcing them to wait for the criminal asset recovery process to conclude—a process that can take years.
When depositors are required to prove to the bank that they have the right to retrieve their own money, this relationship is no longer one of depository banking but has effectively become one of control. The bank is not a service provider but rather an entity that exerts pressure, manages, and controls.
In a financial system governed by the rule of law, the burden of proof naturally falls on the bank: the bank must demonstrate that it has legal grounds to refuse payment. In today’s China, however, this burden of proof has quietly been reversed. Depositors are no longer clients but rather subjects under scrutiny who must constantly prove their own innocence.
Faced with such a structure, what can depositors actually do to protect themselves? It seems there is little room to find an answer to this question within the current system.
