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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

All posts by Eric Carlson

Eric Carlson: Chinese Government Releases New Judicial Interpretation on Bribery and Corruption

Yesterday, China’s two main judicial agencies released a joint judicial interpretation on bribery, corruption, and misappropriation of official funds.

This interpretation provides additional clarity in understanding the amendments to the Criminal Law that took effect last year, most notably by (1) expanding the definition of bribes to include certain intangible benefits, (2) clarifying that bribes given after benefits are received are indeed bribes, (3) establishing monetary thresholds and standards for bribery prosecutions, including raising the thresholds for bribes involving government officials and non-government officials, and (4) providing additional details on the requirements and benefits of voluntary disclosure.… Continue Reading

The fapiao compliance mystery (Part 2 of 4): An illustrated guide

Part 1 of this series explained what fapiaos are and why they are used.  Today, we examine the different types of receipts and fapiaos in China.

With the exception of small businesses in small cities, most businesses have cash registers and can issue a point-of-sale receipt (收据 or 小票) that would look familiar to someone outside of China. … Continue Reading

Unlocking a mystery of China compliance: Fapiaos (Part 1 of 4)

Machine printed fapiao (restaurant)Anyone who has spent time dealing with compliance issues in China has come across the fapiao (发票). This four-part series will try to explain (1) what a fapiao is, (2) the different types of fapiaos and receipts in China, (3) how fapiaos can be misused for fraud, embezzlement, and corruption, and (4) ways to counter these schemes to minimize compliance risk.… Continue Reading

China considers banning officials from receiving monetary gifts

Draft amendments to China’s Criminal Law currently under consideration would subject government officials who receive certain money or property to criminal penalties.

The current version of China’s Criminal Law prohibits government officials from receiving “money or property” (财物) — or other parties from providing money or property to officials — only when an official takes advantage of one’s position to solicit money or property from others, or illegally accepts money or property from others, in order to seek “benefits” for others (see Articles 385 and 388). … Continue Reading

Meet the Regulators, China Edition

Local criminal and administrative anti-bribery enforcement in China has been much in the news lately. I have received many questions from clients over the years regarding who these different regulators are and what power they have to investigate, prosecute, and enforce criminal and administrative bribery charges.… Continue Reading

The FCPA Resource Guide in Chinese

A common problem I encounter in my practice is the shortage of Chinese-language materials on anti-corruption topics. China-based employees often want to know more about the FCPA and anti-corruption enforcement, but nearly all of the most valuable resources are available only in English.… Continue Reading