Look up the USCC, who owns it, and how they get paid — a PDF code of conduct is not due diligence.
Third-party risk in China is where FCPA/AUCL cases actually live: distributors, finders, travel agents, ‘consultants’. Minimum DD is licence/USCC, UBO, adverse media, whether they can lawfully do the work, and whether commissions match the market. Higher risk (government, hospitals, exclusive distributors) needs more. Refresh when the payment pattern changes. Distributor-specific risks are a related pages. UBO wiki stays linked. Do not outsource DD to the third party’s cousin.
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.
Who is the legal person?
USCC, not a brand.
IDWho owns them?
UBO.
UBOWhy this fee?
Market vs pass-through.
FeeCan they legally perform?
Scope and licences.
CapacityWorking 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 a SAMR search enough?
It is the start, not the file. Payment flow is usually the tell.
Where is UBO?
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.