The plan breaks down securities brokerage business into four steps: marketing, account opening, trading instructions, and fund transfers. If any step is implemented, it is considered illegal—this essentially blocks all gray-area channels for overseas institutions to bypass regulations, directly maximizing compliance costs.

Crypto界.com news, officials from the China Securities Regulatory Commission stated in response to a reporter's question about the "Implementation Plan for Comprehensive Rectification of Illegal Cross-Border Securities, Futures, and Fund Activities" that foreign institutions that operate in China without approval from the State Council's securities and futures regulatory authority, either directly or through their affiliates or partners, engaging in securities, futures, or fund business within China, constitute illegal activities.
Foreign institutions primarily conduct cross-border operations related to securities brokerage, including marketing and solicitation, account opening, processing trading instructions, and fund transfers.
Foreign institutions and related domestic entities that have not obtained the necessary domestic securities business licenses engaging in any of these activities within China are considered to be engaging in illegal securities activities.