Circular 7 replaces Circular 78 and expands SAFE’s current regulation of domestic individuals participating in equity incentive plans of overseas listed companies. Notable changes under Circular 7 include (i) award holders who are “foreigners” in China are now subject to foreign exchange registration, (ii) silence on the Circular 78 restrictions on the source of funds used to exercise awards, and (iii) silence on the Circular 78 requirement to remit all proceeds from the sale of shares underlying the awards back to China.