China Tightens Anti-Corruption Rules, Expands Private Sector Enforcement
Companies with operations, supply chains, or commercial relationships in China face elevated anti-corruption enforcement risk following new lowered bribery thresholds, expanded entity-level liability, and extraterritorial jurisdiction provisions for Chinese regulators.
In the first half of 2026, Chinese regulators implemented the first major update to the country’s criminal bribery judicial interpretation in a decade, effective May 1 2026, which lowers bribery and corruption thresholds for non-state actors and revises standards for entity-level liability for companies and other organizations. The State Administration for Market Regulation also issued immediate-effect guidance enforcing the revised Anti-Unfair Competition Law, which for the first time explicitly penalizes bribe acceptance and asserts extraterritorial jurisdiction over misconduct disrupting China’s domestic market order. Enforcement remained robust, with 245,000 anti-corruption cases opened in Q1 2026 and high-profile investigations of former senior financial and provincial officials for family-linked corruption. Companies with China ties should update anti-bribery compliance programs to account for lowered liability thresholds, expanded entity enforcement risk, and extraterritorial AUCL exposure, and enhance due diligence on third-party partners and officials’ family members.