I would like to ask a question about China's SAFE regulation.

I am currently employed with a Listed Company outside of China. And I am considering an offer to relocate to China, transferring the employment to the Domestic Company in China.

  • The Domestic Company is a subsidiary of the Listed Company outside of China.
  • I was granted restricted stock units (RSU) by the Listed Company and by now some RSU are partly vested already.

I know that China's SAFE regulation requires that all domestic employees' foreign exchange transactions related to the Listed Company stocks are to be centrally managed by the Domestic Company.

My question is, when I am relocated to China, will my prior vested shares become centrally managed by the Domestic Company as well, such that if I liquidate the shares, the proceed will now need to go through the Domestic Company?

  • I think this question might be better suited for Finance.
    – ouflak
    Nov 4, 2021 at 21:54
  • @ouflak but this is not a finance question, its on foreign exchange policy. I'm in finance.
    – Rosetta
    Nov 10, 2021 at 7:49
  • I just think that there aren't going to be too many posters here that will be able to really help you with this question. No doubt foreign is a major topic for expats. but I think it's rare that many of us have to have this degree of intracy and specific knowledge. A site with more people aware of currency policy, investments, and China in particular, might get you some useful responses. We don't get a lot of traffic here (Finance does). If there is another SE site you'd like this on, I can move it over.
    – ouflak
    Nov 10, 2021 at 10:28

1 Answer 1


I believe it depends on where your job was coded (US or China) when the prior shares vested. Your company's stock plan/compensation administrator should be able to review your grant(s) and internal status to determine the quantity subject to SAFE vs. not. You can go through your employer's benefits and HR office/hotline usually.

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