What isAgency export,No Foreign Exchange Settlement?

Non-settlement of foreign exchange for export agency refers to the operational model where a foreign trade agency company, after accepting a commission to export goods, does not settle the foreign exchange income through the banking system as required. Instead, it retains the foreign exchange overseas or transfers it through other channels. According to the "Detailed Rules for the Administration of Foreign Exchange in Cross-Border Trade" in 2025, foreign exchange earnings from legal trade exports should, in principle, be settled within 90 days after the goods are exported.Collecting Connection.

Is this kind of operation really legal?

Under specific business scenarios, there may be room for operation, but strict conditions must be met:

• A genuine trade background: A complete version is required.customs clearanceInvoice, shipping documents, commercial invoice
• Basis for foreign exchange retention: Compliant with special policies such as cross-border capital pools and overseas contracting projects
• Compliance operation path: Through regulatory channels such as the NRA account in the free trade zone and the cross-border e-commerce 9710 model.

In 2025, the State Administration of Foreign Exchange specifically emphasized that it is prohibited to evade foreign exchange supervision through means such as fabricating trade or reusing customs declaration forms.

What are the main risk points?

• Foreign exchange retention risk:
  • Enterprises with outstanding foreign exchange receipts exceeding 90 days will be classified as Category B for regulatory purposes.
  • Accumulated amounts exceeding $5 million may trigger on-site verification.
• Tax inspection risk:
  • Unable to match.Export tax refundForeign exchange receipt certificate
  • May be identified as fraudulent export tax refund claims.
• Risk of trade disputes:
  • Payment disputes caused by difficulties in tracing fund flows
  • Cases of agencies misappropriating foreign exchange funds have increased by 37% in recent years.

The core points of compliance operations

• Confirm the applicability of foreign exchange policies:
  • Cross-border e-commerce B2B direct export (Model 9710) allows for a 30-day deferred foreign exchange receipt.
  • Pilot enterprises engaged in offshore trade in the free trade zone may apply for foreign exchange retention quotas.
• Document Management Triple Verification:
  • Customs declaration documents and transport documents time logic matching
  • Consistency between foreign exchange recipient and exporter information
  • Correspondence between Fund Flows and Trade Contracts
• Capital Route Specification:
  • Give priority to cross-border RMB settlement via banks.
  • The offshore capital pool must complete the macro-prudential filing with the central bank.

How to choose a reliable agency company?

It is recommended to evaluate partners from three dimensions:

• Qualification review: Check the State Administration of Foreign Exchange's Class A Enterprise Certification and Customs Advanced Certification Qualification
• Business transparency: Request real-time tracking of customs declaration and foreign exchange collection progress, and reject the commingling of funds in a pool.
• Wind control system: Confirm the presence of a trade background review system and a foreign exchange risk early warning mechanism.

A case study of an electromechanical export enterprise in 2025 demonstrated that by reasonably retaining $2 million in foreign exchange through an NRA account in the free trade zone and providing complete engineering contracting contracts, the company successfully avoided foreign exchange compliance risks. This proves that compliant operations require professional program design and strict execution.

Special Reminder: The 2025 revised edition of the "Export Foreign Exchange Collection Management Measures" has clarified that for agency export businesses, the foreign exchange collection procedures must be handled by the agent. Direct foreign exchange collection by the principal will result in administrative penalties. It is recommended that enterprises establish a comprehensive foreign exchange management system and consult professional customs advisors when necessary.