Welcome back to bribes, swindle, or steel. This is Alexandra Ragi, and it's Hong Kong

week for the podcast. I'm spending the week here with a full schedule of meetings organized by

the Independent Commission Against Corruption, the ICAC. We're launching the week with a look at the compliance landscape of Hong Kong,

and joining me for this is Wendy Wysong from Trace's partner firm, Clifford Chance.

Wendy leads the Asia-Pacific anti-corruption and trade controls practice for Clifford Chance.

She joined the firm after serving first as an AUSA in Washington and then as the Deputy Assistant

Secretary for Export Enforcement at the Bureau of Industry and Security at the Department of Commerce.

Wendy, thank you for joining me.

Thank you.

Can you start by just describing the compliance environment in Hong Kong?

Sure.

Generally, with regard to anti-corruption, as one would expect for a country that ranks in the top 15 or 16 for risk, Hong Kong is very much perceived to be quite compliant.

The primary piece of legislation in Hong Kong is the prevention of

bribery coordinates or the POBO. And it's an interesting law. It's primarily focused on public

sector bribery. It uses a very broad term to characterize what a bribe could be.

It uses the word advantage, and that basically means anything of value.

And it's defined a lot like the same terms that the FCPA would cover.

Except it's really detailed, right?

I saw the definition, the Ministry of Justice and, or Department

of Justice, and I don't think I've seen as comprehensive a definition as that. That is true. It's a

very long laundry list, just in case there's any room for doubt as to what might be encompassed

within an advantage. But interestingly, they do exclude entertainment that is consumed on site.

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