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ARTICLE · 09 SEPTEMBER 2026

China Issues Draft Anti-Cross-Border Corruption Law

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China has released its first comprehensive draft law targeting cross-border corruption, establishing new processes for international cooperation in investigations and imposing compliance obligations on companies engaged in cross-border business. The Draft Anti-Cross-Border Corruption Law introduces a coordinated enforcement model led by the National Supervisory Commission and incorporates counter-sanctions provisions, raising critical questions about how foreign companies and their Chinese subsidiaries will

ChinaCriminal Law

On August 28, 2026, the Standing Committee of the National People's Congress (NPC) released the Draft Anti-Cross-Border Corruption Law (中华人民共和国反跨境腐败法(草案), the Draft ACBCL) for public comment. If enacted, the Draft ACBCL would be China’s first comprehensive law addressing cross-border corruption. Although the Draft ACBCL does not define new crimes, it establishes processes for inter-agency and international cooperation in the investigation of cross-border corruption, and has the potential to affect companies’ compliance programs and the conduct of cross-border investigations. Comment on the draft is due by September 26, 2026.

Background and Context

Over the past decade, China has revised its anti-corruption framework through amendments to the Anti-Unfair Competition Law (AUCL), Criminal Law, and Supervision Law. In 2011, the 8th amendment to the Criminal Law first established the crime of bribing foreign government officials and personnel of international organizations.

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