近年来,随着外汇监管由事前向事后的转变,事后监测和行政处罚工作的重要性更加凸显。但在实践中,外汇行政执法也面临取证难、定性难、处罚难等问题。本文借鉴美国摩根大通“马多夫”庞氏骗局案件和解的相关内容,从引入和解制度、创新惩戒方式等方面,对完善我国外汇行政执法提出政策建议。我国外汇行政执法难点违规行为隐蔽性强,非现场线索捕捉难度明显增加。近年来,为适应经济环境的发展变化,外汇局积极调整管理理念与方式。其中,“五个转变”明 In recent years, with the change in foreign exchange supervision from ex ante to ex-ante, the importance of ex post monitoring and administrative punishment has become even more prominent. However, in practice, the administrative enforcement of foreign exchange is also facing the difficulties of obtaining evidence, making it difficult to identify qualitatively and penalties. This article draws lessons from the settlement of the JP Morgan Chase “Madoff ” Ponzi scheme from the introduction of reconciliation system, innovation and disciplinary methods, to improve China’s foreign exchange administration and law enforcement policy recommendations. Difficulties in China’s foreign exchange administration and enforcement violations hidden covert, non-site clues significantly increased the difficulty of capture. In recent years, in order to meet the development and changes in the economic environment, the SAFE has actively adjusted its management concepts and methods. Among them, “five changes ” Ming