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Alexandra Wrage
President and Founder, TRACE


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Nicola Bonucci 
International Lawyer and former
Director for Legal Affairs OECD
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Dave Lee
FCPA Compliance Consultant, TRACE
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Sunny McCall
Senior Director II, Compliance Training, TRACE
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Lee Nelson
Independent Compliance and
Ethics Attorney
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Jessica Tillipman
Associate Dean for Government Procurement Law, The GW University Law School
  • Writer's pictureDave Lee

China’s First Foreign Bribery Case

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Last fall, a court in China sentenced two former executives of a state-owned railway company to prison for bribing a foreign official in Singapore. It appears to be the first time that China has prosecuted a foreign bribery case.

Given that some scholars have harshly criticized China for not enforcing its foreign bribery laws (notwithstanding that this critique could well apply to most nations), a case involving roughly $160,000 in bribes to a seemingly ineffectual transit official may appear anticlimactic.

But China has long made it clear that it is going after both “tigers and flies,” and the move sends an important message to lenders, borrowers, contractors, and government officials that connect to the country’s outbound infrastructure investment outlay, the Belt and Road Initiative (“BRI”): no crime is too small.

While divinations about China’s motives should often be taken with a proverbial grain of salt, curbing extraterritorial corruption – alongside other legal safeguards  – is consistent with a more measured approach to managing commercial risk. With up to half of infrastructure spending being lost to corruption, China would benefit from pursuing (and ideally preventing) BRI-related misconduct in countries where laws are not well-enforced.

Already, roughly $56 billion worth of China-backed infrastructure projects in 49 countries were suspended by the end of 2021, according to a report last November by AidData, and China is owed more than $850 billion from countries in financial distress.

Put simply, if China wants its loans repaid (and the data suggests that it really does), it must reduce bribe-giving in BRI projects  – including by its own people. In addition, as China steadily seeks to spread its commercial risk and include more multinational partners and commercial banks in its infrastructure lending activities, it will have to offer (or at least go along with) more robust oversight and enforcement.

FCPA Compliance Consultant, TRACE



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