China Compliance Update — December 2025

Recent announcements from the Chinese Supreme Court show that China is aggressively pursuing its anti-corruption campaign. In the first half of 2025, Chinese courts nationwide concluded 4,842 cases relating to acceptance of bribes, embezzlement, and misappropriation of funds in the private sector, a year-on-year increase of 11.6%. In the public sector, data released by the Central Commission for Discipline Inspection of the Communist Party of China (CCDI) on October 29, 2025 shows that from January to September 2025, the CCDI initiated 789,000 investigations into government officials who potentially accepted bribes, investigated 25,000 individuals for paying bribes, and transferred 3,127 individuals for criminal prosecution.

On December 9, 2025, the Supreme People’s Court and the Supreme People’s Procuratorate jointly released Model Cases On Punishing Corruption Crimes that Occur Around the People In Accordance With the Law, which included five model cases and further demonstrated Chinese regulators’ focus on strengthening anti-corruption enforcement at all levels.

The five cases published followed on the publication of model cases by the Supreme People’s Court and the Supreme People’s Procuratorate in November 2025 and March 2024, and covered multiple areas, including housing security, elder care services, China’s state-run medical insurance program, school meals, and the protection of people with disabilities. One of the five model cases published in December is notable for implicating a county-level healthcare official who was found to have engaged in corrupt behavior, signaling Chinese regulators’ continued focus on medical insurance fraud.

For questions on this or any other subject, please reach out to the authors or any of their colleagues in Arnold & Porter’s Life Sciences or White Collar Defense & Investigations practice group.

Zhewen Zhang contributed to this Blog.

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