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Provided by Sandra Lu
Retail Funds, Private Funds, Asset Management and Financial Institutions
Ms. Lu has respectively obtained Bachelor Degree of Economic Law and Master Degree of International Economic Law and was PRC qualified in 2004. Ms. Lu worked in two reputable PRC law firms from 2002 to early 2009 and joined Llinks as a partner from March 2009. Currently Ms. Lu is the partner of Llinks responsible for securities investment funds and asset management practice.
Ms. Lu has extensive experience and expertise in securities investment funds which are highly regulated by the CSRC (the “Fund”) and other types of products including the private funds and hedge funds.
In Funds area, Ms. Lu represented a large number of Chinese financial institutions like the commercial bank, insurance company, securities firm and trust company to set up the fund management company (the “FMC”) in China. Ms. Lu also represented over 15 global asset managers to set up the JV FMC in China including helping them to understand the regulatory environment of China, participating commercial negotiation with their Chinese partners, drafting the shareholders agreement and articles of association of the proposed JV FMC and preparing all application documents for JV FMC establishment and submitting to the CSRC. Ms. Lu also advised a large number of domestic and foreign financial institutions to acquire the stake the Chinese FMC.
The PRC counsel shall issue the formal legal opinion for each of the Fund launch according to the PRC Securities Investment Law, which is a part of the application package to be submitted to the CSRC. Ms. Lu and her team have advised over 1,500 Funds for their application to obtain CSRC’s approval. All such Funds include equity funds, fixed funds, bond fund, money market fund, LOF and ETF.
Ms. Lu is highly involved in the innovative Funds products in the Chinese market including providing the legislative advice to the regulator and the legal advice to the fund houses. The innovative Funds Ms. Lu advised on include the cross boarder EFT, cross market ETF, gold EFT, commodity ETF, principal guaranteed product, the publicly offered REITs, the publicly offered PE investment fund and the publicly offered leveraged investment product, etc..
In the meanwhile, with the development of the global investment capability of the Chinese FMCs, Ms. Lu acts as the legal advisor for a majority of the QDII Funds offered in China. In addition, Ms. Lu is very active in QDLP and QDIE initiatives respectively launched by Shanghai and Shenzhen. QDLP and QDIE products provide the opportunity for the Chinese investors to get a broader global exposure, and also the opportunity for the global asset managers to set up onshore WFOE entity to raise money directly from the Chinese investors.
QFII and RQFII are the main practice area of Ms. Lu as well. Ms. Lu assist the QFII and RQFII to apply for the Chinese license and quota, support their ongoing legal and compliance requirement and review their offshore offering documents from the PRC perspective.
Recently, Ms. Lu has been advising a number of HK fund managers for their MRF application with the CSRC and providing the ongoing legal and compliance services under MRF scheme.
Ms. Lu is often invited by regulators and self-disciplined funds association to provide legislative advice.
Mandarin and English
Provided by Chambers
Sandra Lu is well regarded for her investment fund practice, handling both public funds and private equity funds. Her clientele includes financial institutions, securities firms and trust companies.
吕红律师以其投资基金业务而备受好评，处理公募基金和私募股权基金。她的客户群包括金融机构、证券公司和信托公司。
7 items provided by Llinks Law Offices
Implications of New Mainland Rules on Retail Fund Distribution Fees for Northbound MRF Funds
On 31 December 2025, the China Securities Regulatory Commission (“CSRC”) released the Provisions on the Administration of Distribution Fees for Publicly Offered Securities Investment Funds (“Distribution Fee Rules”).
CSRC Unveils Work Plan to Optimize the QFI Regime
On October 27, 2025, China Securities Regulatory Commission (“CSRC”) publicized the Work Plan for Optimizing the Qualified Foreign Investor Regime (“Work Plan”) (The full translation is attached to this article) on its website.
Futures Exchanges Released the Administrative Measures for Program Trading
This article summarizes the key aspects of the Administrative Measures, serving as a reference for traders and relevant institutions engaged in futures program trading.
Program Trading Reporting by Stock Connect Investors
On 11 July 2025, the Shanghai Stock Exchange (“SSE”) and the Shenzhen Stock Exchange (“SZSE”) respectively released the Guidelines No.2 on the Application of Securities Trading Rules of the Shanghai Stock Exchange.
CSRC Released the Provisions on Futures Program Trading
On 13 June 2025, the China Securities Regulatory Commission (“CSRC”) released the Provisions on the Administration of Program Trading in the Futures Market (Trial) (《期货市场程序化交易管理规定(试行)》) (“Futures Program Trading Provisions”), which will take effect on 9 October 2025.
Internationalization of SHFE Rules, Granting More Access to Overseas Participants
The SHFE Rules aim to align the SHFE’s regulatory framework with international standards across five key areas: market access, trading, clearing, risk control and delivery.
MRF 2.0 Goes Live: Optimizing MRF Scheme and Expanding Cross-Border Business Opportunities
Nearly a decade after the implementation of the Mainland-Hong Kong Mutual Recognition of Funds (MRF) scheme (“MRF Scheme”), it is further optimized, releasing greater policy flexibility and business opportunities.
Implications of New Mainland Rules on Retail Fund Distribution Fees for Northbound MRF Funds
On 31 December 2025, the China Securities Regulatory Commission (“CSRC”) released the Provisions on the Administration of Distribution Fees for Publicly Offered Securities Investment Funds (“Distribution Fee Rules”).
CSRC Unveils Work Plan to Optimize the QFI Regime
On October 27, 2025, China Securities Regulatory Commission (“CSRC”) publicized the Work Plan for Optimizing the Qualified Foreign Investor Regime (“Work Plan”) (The full translation is attached to this article) on its website.
Futures Exchanges Released the Administrative Measures for Program Trading
This article summarizes the key aspects of the Administrative Measures, serving as a reference for traders and relevant institutions engaged in futures program trading.
Program Trading Reporting by Stock Connect Investors
On 11 July 2025, the Shanghai Stock Exchange (“SSE”) and the Shenzhen Stock Exchange (“SZSE”) respectively released the Guidelines No.2 on the Application of Securities Trading Rules of the Shanghai Stock Exchange.
CSRC Released the Provisions on Futures Program Trading
On 13 June 2025, the China Securities Regulatory Commission (“CSRC”) released the Provisions on the Administration of Program Trading in the Futures Market (Trial) (《期货市场程序化交易管理规定(试行)》) (“Futures Program Trading Provisions”), which will take effect on 9 October 2025.
Internationalization of SHFE Rules, Granting More Access to Overseas Participants
The SHFE Rules aim to align the SHFE’s regulatory framework with international standards across five key areas: market access, trading, clearing, risk control and delivery.
MRF 2.0 Goes Live: Optimizing MRF Scheme and Expanding Cross-Border Business Opportunities
Nearly a decade after the implementation of the Mainland-Hong Kong Mutual Recognition of Funds (MRF) scheme (“MRF Scheme”), it is further optimized, releasing greater policy flexibility and business opportunities.