Focus On China Compliance - October 2015

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog's October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29 mentions. This statistic may well increase in the next 12 months as the long arm of FCPA enforcement has extended to cover individual employees more aggressively, including those working at non-US companies, even if they live and work outside the United States. In addition to the effects of foreign legislation, China has this year experienced an outbreak of compliance-related laws and enforcement campaigns. Most notable are those relating to environmental protection before and after the Tianjin explosion, and the Ninth Amendment to the PRC Criminal Law, which has impacted corruption, personal privacy, and data security. This issue reviews some of the most significant changes from the last 12 months, and their practical impact on businesses.