In November 2011, Apple's iTunes Store started accepting renminbi payments in order to make it easier for Chinese customers to purchase apps and digital goods. Apple was able to accomplish this goal by pairing up PayEase, a local third-party provider of payment services, which collects money from Chinese customers and then transfers it out of the country. In my view, such a business model may violate China's foreign exchange laws.

When PayEase receives payments denominated in the yuan, it must convert this currency into US dollars before paying iTunes. Since iTunes doesn't have a corporate bank account in China, PayEase must either convert the renminbi it receives domestically or make the conversion offshore.

In February, the State Administration of Foreign Exchange instituted a pilot program in five cities which allows transaction service companies like PayEase to offer cross-border foreign exchange payment services. Cross-border yuan payments though are still prohibited.

The author is You Yunting, a lawyer at Shanghai-based DeBund Law Offices.