STRATEGY
In August 2026, the Standing Committee of the National People’s Congress of China submitted the Draft Anti-Cross-Border Corruption Law[1] for its first reading. This bill marks Beijing’s first unified legislation explicitly targeting cross-border corruption.
The draft law does not only target state-owned enterprises and Chinese nationals abroad, it also applies to foreign entities and their subsidiaries whenever an act of corruption has a link to China, such as bribery of Chinese public officials, private-to-private commercial bribery, or harm to national economic interests. The draft imposes a strict criminal framework, internal compliance obligations and reporting duties on any company linked to Chinese value chains.
A response to the extraterritoriality of US and European laws
For two decades, the United States has been imposing its legal hegemony on a global scale through the use of the dollar and US financial infrastructure[2]. For its part, the European Union has developed the concept of the ‘Brussels Effect’[3], imposing its environmental, social and regulatory standards (ESG[4], GDPR[5], CS3D duty of care[6]) as conditions for access to its single market.
For China, this new anti-corruption law is part of a strategy of ‘lawfare’ (war through the law)[7] and geopolitical rebalancing. By establishing its own extraterritorial jurisdiction, Beijing aims, on the one hand, to counter US unilateralism and challenge the monopoly of Western jurisdictions over the regulation of global trade and, on the other hand, to neutralise the influence of European standards by imposing its own ethical and security compliance standards on global supply chains passing through China or the Belt and Road Initiative.
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