China Sharpens Enforcement Amid Rising National Security, Critical-technology And Overseas Misconduct Risks

China updated its framework on commercial bribery and introduced new legislation to enhance oversight of government officials as part of its anti-corruption efforts. Enforcers can now impose administrative penalties on both payors and recipients of commercial bribes, as well as responsible individuals.

This means that private entities that were typically not the target of supervisory commissions may also be involved in supervisory investigations or inquiries. Foreign multinational companies operating in China and their employees are likely to face increased ABA-related compliance, especially when dealing with state entities, state-invested counterparts, or public resources.

The anti-money laundering regime was also strengthened in China, broadening the law's application scope by expanding predicate offenses and covering non-financial businesses, responsible individuals, as well as overseas money laundering activities.