ODI vs Article 37 Filing: Corporate vs Individual Overseas Investment

The key distinction: ODI is the corporate track (NDRC + MOFCOM + SAFE-bank), while Article 37 refers to SAFE Circular Huifa [2014] No.37 — individual registration for residents who establish or control offshore special purpose vehicles (SPVs) for financing or investment. Common mistake: founders register the company's ODI but ignore their own Article 37 obligations, then cannot legally receive dividends or return funds. Correct sequence matters — typically the individual registers first or in parallel, since some banks ask for 37 registration evidence when processing related transactions. Zhonghui handles both tracks and the coordination between them.