Welcome back to the podcast, bribe, swindle, or steel. I'm Alexandra Rogge, and today we're talking about some anti-corruption developments in China.

Joining me is Wendy Wison. Wendy is the managing partner of Stepto's Hong Kong office. That's also

Trace's partner law firm, so we're very

grateful. Wendy focuses her practice on white-collar criminal defense and international domestic

and regulatory compliance. Wendy, thank you for joining me. Thank you, Alexandra, for inviting me.

China's Central Commission for Discipline Inspection, the CCDI, recently released new guidance on

anti-bribery. Can you walk us through what these changes mean with respect to China's existing

policies and just flesh them out for us a little bit, if you would?

Back in September of 2021, the CCDI issued some guidelines, and they called it the opinions on

further promoting the investigation of bribery and acceptance of bribes. And this really was an

idea that was conceived and released by the primary anti-corruption arms of the Chinese Communist Party, that is, the CCDI, and the

National Supervisory Commission, and they are currently jointly working on ways to implement

the guidelines. So this confidential party document is not readily available to the public,

but folks have gotten a hold of it. They've translated it,

and you can find it to review. When I reviewed it, I really had three takeaways in looking at it.

And the first one has really gotten the most attention because it's sort of a reversal of the prior way that they were enforcing their

anti-brivery rules. And what they did is they created a blacklist. And so companies and

individuals that are found to have paid bribes in China, whether to public officials or

private persons, are going to be put on this

blacklist. And if you're on that blacklist, you can't conduct business in China. And essentially,

what they've done is they've reversed the practice that had been in place for years,

are really focusing on the bribe takers, the government officials.

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