China Compliance Update: Anti-Corruption — Summer 2026

Anti-corruption remained a top priority for Chinese authorities in the first half of 2026. Regulators issued the first major update to the official judicial interpretation of China’s criminal bribery framework in a decade, took further steps to implement the revised Anti-Unfair Competition Law (AUCL), and kept up a robust pace of anti-corruption enforcement.

Legislative Updates

New SPC/SPP Judicial Interpretation on Corruption and Bribery

On April 10, 2026, the Supreme People’s Court (SPC) and the Supreme People’s Procuratorate (SPP) jointly issued the Interpretation on Several Issues Concerning the Application of Law in Handling Criminal Cases of Corruption and Bribery (II) (Interpretation (II), 关于办理贪污贿赂刑事案件适用法律若干问题的解释（二）).¹ It took effect on May 1, 2026, and is the first major update to the prior interpretation of the criminal law of bribery released by the SPC and SPP in a decade. It follows other recent changes to China’s anti-corruption rules, including amendments to the PRC Criminal Law, the AUCL, and the Supervision Law.

The Interpretation (II) focuses on private-sector crimes and “entity crimes,” meaning crimes that carry liability for companies, public institutions, government agencies, and other organizations. Notably, the Interpretation (II) lowers the thresholds of bribery and corruption crimes for non-state functionaries² and revises the standards for entity crimes and key sectors.

SAMR Notice on Enforcement of the Revised AUCL

The revised AUCL took effect on October 15, 2025.³ Following that, the State Administration for Market Regulation (SAMR) issued the Notice on Further Implementing the Anti-Unfair Competition Law of the People’s Republic of China (Notice, 市场监管总局关于进一步贯彻实施《中华人民共和国反不正当竞争法》的通知) to lower level Administrations for Market Regulation (AMR) on March 30, 2026. The Notice took immediate effect.

The Notice provides guidance to AMRs on areas of emphasis when enforcing the revised AUCL, including an emphasis on investigating and punishing both the payment of bribes and the acceptance of bribes. This focus on both sides of corrupt transactions is an important change in the revised AUCL. The previous version of the AUCL did not explicitly prohibit accepting bribes and did not explicitly list administrative penalties for companies or individuals which accepted bribes, even though such conduct was, in practice, frequently the focus of enforcement actions. The revised AUCL filled this gap, bringing it in line with recent years’ enforcement trends in China.

Another key area of emphasis in the Notice is Article 40 of the revised AUCL, the “long-arm jurisdiction” clause. The Notice encouraged AMRs to explore the use of extraterritorial jurisdiction to target false advertising, online unfair competition, commercial defamation, trade secret misappropriation, and other misconduct outside of China that disrupts China’s market order or harms domestic rights holders, to safeguard the domestic supply chain and the interests of Chinese companies and the state. However, the SAMR has not provided further guidance on how extraterritorial jurisdiction should be exercised in the context of the revised AUCL.

With the publication of the Notice, we anticipate more stringent enforcement actions targeting commercial bribery by the AMR, as well as efforts by local AMRs to implement extraterritorial jurisdiction.

Enforcement Cases

Official statistics released in the first half of 2026 confirm that Chinese regulators remained focused on anti-corruption enforcement.

In the first quarter of 2026, discipline inspection and supervisory commissions opened 245,000 cases and disciplined 183,000 people, including 56 provincial- or ministerial-level officials. In line with the principle of “investigating bribe givers and bribe takers together” (受贿行贿一起查), authorities opened investigations into 9,066 individuals suspected of paying bribes and referred 983 for prosecution.

Three senior officials were investigated, arrested, or charged with crimes of bribery in the first half of 2026:

• Huiman Yi (易会满), former Chairman of the China Securities Regulatory Commission (CSRC) from 2019 to 2024. On April 30, 2026, the Central Commission for Discipline Inspection (CCDI) announced that Yi was subject to disciplinary actions, including being expelled from the Communist Party and removed from any public duty, following a corruption investigation. In addition, Yi’s case has been transferred to the procuratorate for criminal charges. According to the CCDI, Yi abused his regulatory authority to seek benefits for others in matters including IPO approvals and financing activities, while accepting substantial bribes and allowing relatives to profit from his influence. 
• Chaoliang Jiang (蒋超良), former Communist Party Secretary of Hubei Province. Jiang was prosecuted for bribery and corruption on March 17, 2026. This investigation reaches back more than 30 years to Jiang’s time in the financial sector. He is accused of using his roles at the Agricultural Bank of China, China Development Bank, and the Hubei provincial government to provide improper help with loans, project approvals, and personnel decisions. The case has been publicly labeled “family-style corruption” (家族式腐败) because his relatives allegedly played a central role as conduits for concealed benefits.
• Xingrui Ma (马兴瑞), former Politburo member and Communist Party Secretary of Xinjiang Uygur Autonomous Region. On July 14, 2026, Ma was expelled from the Communist Party and removed from public office following a corruption investigation. The CCDI found him to have abused his position to benefit others in business operations, engineering projects, and personnel matters in exchange for substantial bribes, while allowing relatives to exploit his influence for personal gain. Ma’s case has been referred for criminal prosecution.

These cases illustrate Chinese regulators’ continued emphasis on scrutinizing officials’ family members in 2026. This has been the enforcement focus of bribery and corruption by government and party officials in recent years, particularly since the issuance of the Report at the 20th National Congress of the Communist Party of China in October 2022, which explicitly required enhanced scrutiny over corruption cases involving officials’ family members, including their spouses, children, and other relatives.

© Arnold & Porter Kaye Scholer LLP 2026 All Rights Reserved. This Advisory is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.