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

Who is the legal person?

USCC, not a brand.

ID
02

Does this issue require separate analysis?

UBO.

UBO
03

Why this fee?

Market vs pass-through.

Fee
04

Can they legally perform?

Scope and licences.

Capacity

Working rule: Third-party risk in China is where FCPA/AUCL cases actually live: distributors, finders, travel agents, ‘consultants’.

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
Code of conduct as DD
Signed PDF, no USCC.
Empty.
Success fee to a ‘professor’
Classic finder.
Red flag.
Never refresh
Five-year-old memo.
Stale.
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.

01Licence and UBO printDated.
02Contract and commission scheduleEconomics.
03Adverse-media/SAMR abnormal listIntegrity.
Common confusions

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?

Use the linked specialist resource when Third-Party Compliance Due Diligence in China turns on detailed evidence, procedure or risk assessment.

Primary authorities

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