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

Does this issue require separate analysis?

Related-party check.

Owner
02

What is the extra margin for?

Market vs slush.

Margin
03

Who are their customers?

Official/hospital overlay.

Customers
04

Can you audit and terminate?

Contract.

Control

Working rule: Using distributors is normal. Risk concentrates when the distributor is a former employee’s company, when extra ‘marketing support’ is off-books, when they cover hospitals or government buyers, or when they sell outside authorised scope.

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
Activity fund in cash
Classic.
Stop.
Ex-sales-lead’s new company
COI plus DD.
Conflict page.
Annex policy, no USCC DD
Code of conduct only.
Empty.
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.

01Distributor licence/UBODated.
02Commission vs marketEconomics.
03Downstream customer listWho they wine-and-dine.
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 a distributor make us safe from AUCL?

No. Using a third party is a listed pattern, not a shield.

Where is the contracts distribution page?

Use the linked specialist resource when Compliance Risks When Using Distributors in China turns on detailed evidence, procedure or risk assessment.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.