The classification screen

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.

01

Is the benefit tied to a transaction?

AUCL hook.

Nexus
02

Third party used?

Still counts.

Third
03

SAMR vs PSB?

Administrative vs criminal.

Track
04

Books and fapiao?

How it will be proved.

Proof

Working rule: 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.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal
Ask the operating question
Why it changes the route
Only FCPA analysis
No AUCL count.
Gap.
Broader Investigations & Compliance analysis needed
Do the facts extend beyond the threshold Anti-Unfair Competition Law Bribery Rules question?
Additional facts can change the Investigations & Compliance route, evidence and next step.
Ignore hospital/medical overlays
Only a general AUCL memo.
Sector rules on top.
Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Payment trailWho got the benefit.
02Tender or supply contractThe advantage sought.
03Third-party invoicesPass-through.
Common confusions

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.

PRC Anti-Unfair Competition Law (NPC)
SAMR
Supreme People’s Procuratorate
National laws database (NPC)