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

Bribery facts or monopoly facts?

Do not mix the files.

Label
02

Administrative vs criminal?

Amount, official vs commercial.

Track
03

Third parties in the middle?

Distributor DD related topic.

Third
04

Gifts policy actually followed?

Gifts related topic.

Gifts

Working rule: Kickbacks to customers, doctors, or distributors can be AUCL administrative cases or crimes depending on facts.

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
AML means money-laundering only
Missing SAMR antitrust.
Ambiguous English.
use commercial-bribery slug
Second related guide.
Do not.
FCPA memo as PRC file
No AUCL analysis.
Incomplete.
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 and gift trailWho received what.
02Counterparty typeOfficial, hospital, customer, distributor.
03Policy and approvalsWhat the company said vs did.
Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Is commercial bribery a crime?

It can be, above thresholds and with the right defendant. Many cases stay administrative. Do not guess.

Where is the AUCL detail?

Open /anti-unfair-competition-law-bribery-rules.

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)