AUCL bribery is administrative commercial-bribery — Criminal Law is the harder twin, not a synonym.
The Anti-Unfair Competition Law prohibits giving or taking bribes to sell or buy goods, including benefits to organisations or individuals that can influence a transaction, and using third parties to do it. SAMR investigates; fines and confiscation follow. Criminal Law (offering/accepting bribes, including to non-officials in some articles) is a separate, higher stack. This scoped page is the AUCL text. The live basics URL stays the orientation main guide — we did not create /commercial-bribery-in-china. Gifts and distributors apply the rule.
4 questions before you choose the route.
This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.
Is the benefit tied to a transaction?
AUCL hook.
NexusThird party used?
Still counts.
ThirdSAMR vs PSB?
Administrative vs criminal.
TrackBooks and fapiao?
How it will be proved.
ProofWorking rule: Map the regulated role before marketing or launch in China.
The signal ledger.
These facts move the question beyond a label and into a product, money-flow and control analysis.
Bring a compact evidence docket—not a pitch deck.
Give a compliance team or counsel the operating facts that reveal the perimeter.
Questions people ask before they build.
Short answers for orientation. The right result can change with the service model and current rules.
Does AUCL need an ‘official’?
No. Commercial counterparties are in scope. Officials add Criminal Law risk.
Why not a second basics slug?
Live /china-aml-anti-bribery-basics already owns orientation.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.