Private actions & compliance · 06 Editorial guide

China Private Antitrust Claims and Compliance Programmes

Civil-claim, programme and audit questions after the competition issue is framed.

First job Separate follow-on exposure from the authority process.

Decision railconduct owner → evidence → claim or defence → programme fixes

Direct answer

What this page decides

Owner
01

This page owns civil follow-on and stand-alone AML claims and the compliance-programme overlay. It does not retry merger filing or rewrite RPM. A SAMR decision helps but is not always required. Damages, standing and evidence are court questions — no invented multipliers.

At a glance

Which fact changes the next route

Use the fact that changes ownership or urgency to decide the next move.

Facts that change the next investigation route
Question	Why it matters	Next route
Still deciding if RPM is illegal?	Wrong page.	Vertical L4.
Customer threatening suit?	This page.	Preserve; counsel.

Scope

What this page owns — and what it does not

Owns private actions after the conduct is framed.

ExclusionsSAMR raid (Investigations L4).

Practical workflow

Action, evidence, legal gate, output

Practical workflow
Action	Documents / evidence	Legal gate	Output
Name the conduct L4	Which theory	Horizontal/vertical/dominance	Theory
Preserve civil evidence	Contracts, prices, communications	Hold	File
Claim or defence posture	Standing, harm, pass-on	Counsel	Litigation memo
Programme remediation	Policies, training, audits	Not a PR PDF	Controls

Documents

What to gather before the next call

These items help clarify the file; they are not a legal requirement list.

Documents to gather before instructing counsel
Item	Why needed	Who holds it	Risk if missing
Underlying agreements and prices	Civil record	Legal	Empty complaint or defence
Any SAMR decision	Follow-on	GC	Inconsistent admissions

Common failure points

Where files usually break

Waving a compliance certificate as if it erased RPM emails.

FAQ

Narrow follow-ups owned by this page

Can a claimant sue without SAMR?

Often yes on a stand-alone theory. Evidence still has to exist.

Curated resources

Open the asset that matches this job.

Guide

China antitrust decision desk

National decision desk for merger control, conduct and investigations. This remains the long-form owner.

Guide

Sources and follow-on questions

Use the desk sources block for private-action and compliance orientation.

Counsel hand-off

What to bring when you instruct

Instruct antitrust litigation counsel. Bring: the conduct file and any authority decision.

Local context

Add the city only when it changes implementation.

Local SAMR practice can matter after the national question is identified.

Open city and province guides

Counsel hand-off

Need competition counsel?

This hub organises transaction, conduct and investigation routes. It is not a filing decision.

Find competition counsel

Submit an initial enquiry

Legal review

Who reviewed this guide

Need qualified counsel?

Move carefully. Move with a record.

Use the portal to identify counsel for this practice and related China-side issues.

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