China’s Overseas Bribery Law One Year On

As reported previously, in February 2011, China enacted an amendment to its Criminal Law that criminalized paying bribes to non-Chinese government officials and officials of international organizations (“the Amendment”).

The Amendment, which took effect in May 2011, reads:

Whoever, for the purpose of seeking illegitimate commercial benefit, gives property to any foreign public official or official of an international public organization, shall be punished in accordance with the provisions of the preceding paragraph [i.e.,