On 1 December 2017, the State Administration of Foreign Exchange (SAFE) issued the Announcement of the SAFE on Cases of Violating Foreign Exchange Regulations (the SAFE Circular), which includes 20 typical cases concerning (i) evasion of foreign exchange by enterprises and individuals, (ii) non-compliant processing by commercial banks of onshore guarantees for offshore loans (Nei Bao Wai Dai, “内保外贷”in Chinese), and (iii) illegal transfers by non-banking financial institutions of Qualified Domestic Institutional Investor (QDII) quotas. This note will focus on the cases of the latter two categories and analyze their legal implications.