Anti-bribery, anti-money-laundering and internal compliance are related but distinct legal workstreams in China.
Commercial bribery is addressed under the Anti-Unfair Competition Law and can overlap with criminal bribery offences; AML obligations apply to covered institutions and activities under the revised Anti-Money Laundering Law. A corporate compliance program should map actual payment, third-party and customer-risk flows instead of merging the regimes into one generic policy.
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.
Are small festival gifts always illegal?
Not always, but thresholds, recipients, and frequency matter. Policies should define approval, recording, and red lines—not informal custom alone.
Is AML only a bank problem?
Banks are front-line, but companies still face criminal, administrative, and reputational risk from proceeds of crime and sanctions evasion.
Related?
UBO basics · Sanctions basics.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.
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