When kickbacks cross into Criminal Law, you are past a SAMR fine memo — PSB/procuratorate procedure takes over.
Commercial bribery sits in two stacks: Anti-Unfair Competition Law administrative enforcement and Criminal Law offences (including bribery involving non-state staff in covered settings, and official bribery when public officials are involved). Amount, recipient type and purpose drive which stack. Compliance gifts pages and AUCL wiki remain the prevention/administrative related pages. This page is the criminal overlay for the expansion map. Dawn-raid and internal-investigation pages are how companies experience the file before charges.
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.
Official or commercial counterparty?
Article family.
WhoAUCL file or criminal file?
Which agency.
StackThird-party pass-through?
Distributor DD overlay.
ThirdInternal hold underway?
Investigations cluster.
HoldWorking 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.
Is AUCL bribery automatically a crime?
No. Criminal Law has its own elements and thresholds. Many matters stay administrative.
Where is the AUCL statute wiki?
Anti unfair competition law bribery rules and /china-aml-anti-bribery-basics.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.