On 12 October 2026 the Chaoyang Branch of the Beijing Municipal Public Security Bureau announced that a criminal investigation had been opened against Yixin-related companies on suspicion of illegal and criminal conduct; the actual controllers, Tang (male, 53) and Zhao (female, 51), and several other criminal suspects were subjected to coercive criminal measures, and no charge had been announced. This article answers one question only: where the risk lies for people who have already left Yixin.
Charge not yet announcedArticle 176, Criminal Law — illegally absorbing public depositsCommissions and rebates subject to recoveryAnalysis date 2026-11-13For “former employees”, the real dividing line is not whether you still work there, but what you did, what you knew and how much you took. Each of the six points below carries its own conditions; please do not read the headings alone.
Official wording (quoted in part): on 12 October 2026 the Chaoyang Branch of the Beijing Municipal Public Security Bureau announced: “Recently this bureau, in accordance with law, opened a criminal investigation into Yixin-related companies on suspicion of illegal and criminal conduct. At present the actual controllers Tang (male, 53) and Zhao (female, 51) and several other criminal suspects have been subjected to coercive criminal measures in accordance with law.” The same notice asked investors to register their reports online, by post or in person, for the purpose of “establishing the facts of the case in full and recovering the assets and making good the losses with all possible effort”.
Facts on the company side: from 22 May 2026 payments on quasi-fixed-income products stopped across the board; on 11 October a letter of apology was issued to investors through apps such as Ruicheng and Yiren Youxuan, admitting that the company “may be insolvent, with a large shortfall in repayment” and that the underlying assets behind the unpaid products are of poor quality. Media reports put the funds involved in Yixin’s quasi-fixed-income products at about RMB 30 billion; former employees estimate the outstanding balance at RMB 40–50 billion, with nearly 100,000 investors. All of these are media figures, unconfirmed by any judicial authority, and are background only.
Still undetermined: the specific charge; whether a unit crime will be found; which companies are the entities involved; where the money went and what the final loss is; whether employees have already been listed as suspects; and how the scope of recovery will be drawn down to individuals.
Sources: notice of the Chaoyang Branch, Beijing Municipal Public Security Bureau, 12 October 2026; Yixin Group, “Letter of Apology to Clients of Quasi-Fixed-Income Products” (11 October 2026, reported in the media); public media reports.
The crime of illegally absorbing public deposits has four conditions; if one is missing, the offence is not made out. This is the first test of whether the company’s conduct was illegal fund-raising, and the precondition for asking whether an employee “helped illegal fund-raising”.
Employees are drawn in not because they “once worked at Yixin” but because they “provided help in absorbing funds and were paid for it”.
“Knowledge” is not established by the person’s own account, but inferred from objective circumstances.
Applied to an individual wealth manager, the authorities will ask: which type of product was sold; whether the sales pitch contained “guaranteed principal and interest”, “implicit guaranteed repayment” or “the underlying assets are absolutely safe”; whether the person knew the money went into a single account or a pooled-fund structure; whether the person attended training on circumventing regulation or on pooling orders and nominee holding; whether the commission rate visibly departed from industry norms; and whether sales continued before and after the collapse, and whether the person took part in reassurance scripts. Most of this evidence is not in the employee’s hands but in the company’s training system, performance system and work chat groups.
Unit crime and individual liability run in parallel. Article 176(2) of the Criminal Law provides that where a unit commits the offence in the preceding paragraph, a fine shall be imposed on the unit and the persons directly in charge and other directly responsible persons shall be punished in accordance with the preceding paragraph. Articles 2 and 3 of the 2019 Opinions further distinguish parent companies from subsidiaries and the core layer from ordinary participants: where all or most of the illegal gains go to the unit, a unit crime is found; where illegal fund-raising is the main activity, the case is handled as a crime by natural persons; where neither the superior nor the subordinate constitutes a unit crime, the organisers, leaders and managers are treated as principal offenders and other active participants as accessories. This means that a finding of unit crime does not let employees “carry it together with the company”; the individual’s own liability remains.
Accessory status is where most front-line employees land. Article 27 of the Criminal Law: a person who plays a secondary or auxiliary role in a joint crime is an accessory; an accessory shall be given a lighter or reduced penalty, or the penalty shall be remitted.
| Charge | Provision and sentencing bracket | What it means for an employee | Likelihood here |
|---|---|---|---|
| Illegally absorbing public deposits | Article 176, Criminal Law: up to three years; a huge amount or other serious circumstances, three to ten years; an especially huge amount or other especially serious circumstances, ten years or more | Help plus payment is enough for the offence; front-line staff are mostly found to be accessories | Highest — the main entry point |
| Fund-raising fraud | Article 192, Criminal Law: a relatively large amount, three to seven years; a huge amount or other serious circumstances, seven years or more, or life imprisonment | Requires proof of “the purpose of illegal possession”, plus the person’s own common intent and conduct | Low, unless the person took part in fabrication or knew the assets were fictitious |
| Organising and leading pyramid-selling activities | Article 224-1, Criminal Law | Involved only where people are recruited by tier and pay is based on the number recruited | Depends on the product and team structure |
| Illegal business operations | Article 225, Criminal Law | Issuing fund units without approval; selling financial products in disguised form | Particular business lines |
| Money laundering / concealing or disguising criminal proceeds | Article 191 / Article 312, Criminal Law | Helping to move assets, hold them for another, run them through accounts or exchange currency after leaving | Rises markedly once such conduct occurs |
Why fund-raising fraud usually does not reach front-line employees. Article 7 of Fa Shi [2022] No. 5 lists the circumstances from which “the purpose of illegal possession” may be inferred: the funds are not used for production and business after raising, or the use is obviously disproportionate to the scale of the funds raised; the funds are squandered; the raiser absconds with the funds; the funds are used for illegal or criminal activity; funds are withdrawn or transferred to conceal property; accounts are concealed or destroyed, or a false bankruptcy is engineered; and refusal to explain where the funds went. Paragraph 2 of the same article makes clear that where some offenders in a joint crime had the purpose of illegal possession and the others did not share the common intent and conduct, only the former are convicted of fund-raising fraud.
Conversely, where a person knew the underlying assets were fictitious and still took part in designing the product structure, in a pooled-fund structure and rolling over old debt with new money, in fabricating underlying-asset materials, or in organising scripts for dealing with inspections, or where the person’s own share of the returns clearly exceeded normal pay, it is hard to fall back to the illegal-deposit-taking bracket.
Where funds are illegally absorbed by pyramid-selling means and the conduct constitutes both the crime of illegally absorbing public deposits and the crime of organising and leading pyramid-selling activities, conviction and punishment follow the provision carrying the heavier penalty (Article 13, Fa Shi [2022] No. 5).
Separate two concepts first. Article 64 of the Criminal Law says two things: all property illegally obtained by criminals shall be recovered or made subject to an order to make restitution; and the lawful property of victims shall be returned promptly. “Recovery” targets the benefits you received; “an order to make restitution” targets the principal that clients have not recovered. The first is inevitable; the second depends on your role.
| Nature of the money | Recovered / restitution? | Basis | Note |
|---|---|---|---|
| Commissions, sales commissions, rebates, agency fees, benefits, performance-linked bonuses | Subject to recovery | Article 5, 2014 Opinions; Article 26, Regulations on Preventing and Disposing of Illegal Fund-Raising | Leaving, having paid individual income tax, having spent the money — none of these makes a difference |
| Base salary, social insurance, travel reimbursement | Generally not recovered separately, but disputed | Judicial practice | Where the post existed essentially to take deposits, it may be assessed as a whole |
| Unpaid principal losses of clients | An order to make restitution; recovery continues | Article 64, Criminal Law; Article 9, 2019 Opinions | Returned pro rata; a principal offender’s scope is wider |
The administrative regulation is equally clear. Article 25 of the Regulations on Preventing and Disposing of Illegal Fund-Raising (effective 1 May 2021) provides that the fund-raiser and those assisting the fund-raising shall return the raised funds to the fund-raising participants, and that no unit or individual may obtain economic benefit from illegal fund-raising. Article 26 lists the sources for the return of funds, including “the economic benefits obtained from the illegal fund-raising by the fund-raiser and its shareholders, actual controllers, directors, supervisors, senior managers and other relevant persons” and “advertising fees, endorsement fees, agency fees, benefits, rebates, commissions, sales commissions and other economic benefits obtained in the illegal fund-raising” (quoted in part).
So “must it be repaid” is not a question of conscience but of bookkeeping: how much of the commission was tied to the products in question — that is the core figure for repayment.
Three details that are often pressed:
An employee who also bought the products has two capacities. Report and register as a fund-raising participant and be repaid pro rata; that investment cannot be set off against the duty to repay, and the two accounts run separately. In the same way, products bought by an employee’s relatives and friends do not become a personal loan merely because “they were my own clients”.
The figures above are illustrative assumptions, not data from this case, and are not a prediction of any amount for any individual.
| Post | Typical conduct | Risk | Main issue |
|---|---|---|---|
| Front-line wealth manager / relationship manager | Selling products, maintaining clients, taking commission on performance | Medium | Whether the person knew; whether principal and interest were promised; the amount handled personally |
| Team leader / branch or regional head | Organising sales, taking management allowance and team commission | High | Organisational role; may be found to be a principal offender |
| Product design / risk control / finance / legal | Designing the transaction structure, running the accounts, issuing materials | High | Whether the person knew the assets were fictitious; Article 192 may be reached |
| Training lecturer / roadshow speaker | Speaking of “safe underlying assets” and “implicit guaranteed repayment” | Medium-high | Whether the person knew; false advertising or joint crime |
| Back office / customer service / technology / administration | No contact with funds or promotion | Low | Usually not treated as criminal, but an explanation is needed |
| Nominee legal representative / shareholder / holding shares for another | No actual operation, no share of profits | Low to medium | Must show no decision-making and no profit share |
This table only settles “where to look first”, not “whether the offence is made out”. For the same post, the conclusion differs completely depending on whether the product sold was filed by a licensed institution or was a pooled-fund product, whether clients were found personally or came from a company list, and whether the script was company-wide training or personally invented.
The crime has three brackets (Articles 3, 4 and 5, Fa Shi [2022] No. 5): criminal liability arises where the amount is RMB 1 million or more, or the number of persons involved is 150 or more, or direct economic loss of RMB 500,000 or more is caused; an amount of RMB 5 million or more, 500 or more persons, or a loss of RMB 2.5 million or more constitutes “a huge amount or other serious circumstances”; an amount of RMB 50 million or more, 5,000 or more persons, or a loss of RMB 25 million or more constitutes “an especially huge amount or other especially serious circumstances”. There is also a lowered-threshold bracket: an amount of RMB 500,000 or more, or a loss of RMB 250,000 or more, together with any of the circumstances such as a previous criminal pursuit for illegal fund-raising, an administrative penalty within two years, or grave social impact, also attracts criminal liability.
How an employee’s personal amount is calculated decides the bracket directly. It is generally the amount the person took part in absorbing, not a pro-rata share of the company total; team leaders are assessed on team performance, and management on the area they were in charge of. This is the main battleground of the defence, and the reason “I was only carrying out orders” must be proved through job duties, system permissions and approval flows rather than by assertion.
| Role and basis of the amount | Usual bracket | Possible outcome |
|---|---|---|
| Front-line employee, several million to ten or twenty million handled personally, found to be an accessory | Up to three years | A suspended sentence, a fine alone, or exemption from criminal penalty are all possible |
| Team leader, tens of millions, found to be an accessory | Three to ten years, possibly lowered | Around three years or less |
| Senior executive, over RMB 100 million, found to be a principal offender | Ten years or more | Mainly immediate imprisonment |
The table above illustrates the sentencing structure; it is not a prediction for anyone in this case. The actual outcome also depends on repayment, pleading guilty and accepting punishment, surrender and meritorious service, and local sentencing guidelines.
The leniency route operates in sequence: active return of the proceeds and compensation that reduces the harm before the case is committed for trial may lead to a lighter or reduced penalty (Article 176(3), Criminal Law; Article 6, Fa Shi [2022] No. 5); repayment only after committal can be considered only as a sentencing factor in the court’s discretion. Where the circumstances of the crime are minor and no penalty is necessary, a criminal penalty may be exempted (Article 37, Criminal Law); where the circumstances are minor and no penalty is necessary under the Criminal Law or the penalty is exempted, the people’s procuratorate may decide not to prosecute (Article 177(2), Criminal Procedure Law). Surrender, confession, meritorious service and pleading guilty and accepting punishment are counted separately, do not conflict with repayment, and may be combined.
Article 87 of the Criminal Law: where the maximum statutory penalty is less than five years’ imprisonment, the period is five years; five years or more but less than ten, ten years; ten years or more, fifteen years; life imprisonment or death, twenty years. The highest bracket for illegally absorbing public deposits is “ten years or more”, which corresponds to fifteen years. That is, “I left in 2019” is not in itself a conclusive defence; what must be calculated is when the conduct ended and which bracket applies.
The limitation period runs from the day of the offence; where the criminal conduct was continuous or ongoing, it runs from the day the conduct ended (Article 89). Leaving the job is usually the end point, but if the person continued to take commissions, kept servicing clients, took part in a so-called “wind-down” or helped move assets after leaving, the end point moves later. A person who evades investigation or trial after the case is opened is not subject to the limitation period (Article 88).
A private-fund manager sold publicly in the name of a private fund, allowed “pooling orders” and “nominee holding” to break the qualified-investor limit, had an affiliate buy the product back while the actual controller gave a joint and several guarantee in person, and promised annualised returns of 10% to 14.5%, raising RMB 599.9 million in total and leaving investors with principal losses of RMB 441 million. The vice president and head of the sales department and the head of the business department were each sentenced for illegally absorbing public deposits to three years’ imprisonment and a fine of RMB 100,000, and the judgment also ordered that “recovery of illegal gains shall continue”; the authorities froze over RMB 6.87 million in deposits and recovered interest, dividends, commissions and rebates from 35 investors, all to be paid back to the investors once the judgment took effect. Point: registration and filing with the Asset Management Association do not remove the illegality; a senior executive who was not the actual controller but was in charge of sales is convicted all the same; “commissions and rebates” are expressly written into the scope of recovery.
A P2P platform raised funds publicly at 10.8% to 15% annualised, raising RMB 3.513 billion in total and causing losses of RMB 478 million. The directors of credit risk control, marketing and operations were respectively responsible for vetting borrower eligibility, issuing and collecting bids, publicity and promotion, and customer service and website operation. The gist of the judgment states expressly: the finding of a principal offender shall be reviewed comprehensively from the initiation of the criminal intent, the person’s position in the crime, the actual degree of participation, the effect on the harmful consequences, and control over the use of the illegally raised funds; where the actual controller, senior executives and core members each performed their own functions and cooperated with one another, and each played an important role in the crime, all shall be found to be principal offenders. Point: director-level “professional managers” are not treated as ordinary employees; “I did not handle the money” is not the same as “I did not take part”.
Under the names of ejiao, humic acid and “code-washing” business, it was advertised that an investment of RMB 10,000 would return 5% a day from the next day and double in 40 days; “seat fees” rewarded team leaders with 5% to 10% of each day’s intake, and “service fees” paid introducers RMB 20 to RMB 100 per order per day; RMB 652 million was absorbed in total. The actual controller was sentenced for fund-raising fraud to fourteen years’ imprisonment and a fine of RMB 500,000; the finance, logistics and accounting staff and several “team heads” in the same case were pursued as well. The gist of the judgment states: paying high service fees and seat fees out of absorbed funds when the company had no profit at all falls within “funds not used for production and business after raising, or obviously disproportionate to the scale of the funds raised”; transferring funds to buy virtual currency after the funding chain broke and refusing to explain where they went falls within “withdrawing or transferring funds and concealing property” and “refusing to explain where the funds went”. Point: a commission structure that pays for recruiting people and absorbing funds is both evidence of the offence and the factual basis for finding “the purpose of illegal possession”.
At the time of writing (13 November 2026) only one month had passed since the case was opened, and the case is at the investigation stage: there is no indictment, no judgment, and no published list of the persons involved. A search of the statutes and judicial interpretations in force held on the server, the Supreme People’s Court Case Database and the local mirror of China Judgments Online found no effective judgment on facts involving Yixin’s quasi-fixed-income products. The three cases above are structurally comparable references, not adjudications of this case.
The article is therefore positioned as follows: using the rules in force and three comparable cases, it explains the general rules on how employee liability is assessed, and flags the variables that remain uncertain in this case. Any conclusion about a specific individual must wait for the evidence.
The three most uncertain matters: first, the charge — between illegally absorbing public deposits and fund-raising fraud, it depends on where the funds went and on the evidence of the purpose of illegal possession; second, the scope of liability — whether recovery reaches only the individual’s commissions or extends to the unpaid losses of the clients handled, which depends on the finding of principal or accessory; third, the finding of unit crime — if a unit crime is found, individual liability will be expressed differently, but that is not an exemption.
This article is general legal analysis and does not constitute legal advice to any particular person. The outcome of an individual case depends on the period of employment, the product type, the scripts and training content, the commission structure, the client base, the repayment made, and the authorities’ finding on “knowledge”.