Compliance Risk Under DOJ China Initiative | FTI Consulting

Assessing Compliance Risk Under DOJ China Initiative

Forensic & Litigation Consulting | Reprint (Law 360)

March 29, 2019

In late 2018, the U.S. Department of Justice (DOJ) announced new goals and enforcement priorities aimed at countering threats to U.S. national security and economic interests from China in the form of trade secret theft, economic espionage, Foreign Corrupt Practices Act (FCPA) offenses and other violations of U.S. law. Collectively these new goals and priorities are known as the DOJ’s “China Initiative.”

In an article originally published on, Jean Chow-Callam outlines the new risks that Chinese companies seeking to do business in the United States will need to address in the face of increased regulatory scrutiny. Chinese companies and multinationals with cross-border investment should note that regulators will expect strong anti-corruption and anti-bribery compliance programs at any China-related operations, especially high-tech companies that may be involved with “emerging and foundational technologies” such as 5G wireless networks.

The article provides an overview of issues that companies should address in an internal review or risk assessment, and offers some preventative measures to reduce exposure to compliance risk.

Republished with the permission of Law 360. © Copyright 2019. The views expressed herein are those of the author and do not necessarily represent the views of FTI Consulting, Inc. or its other professionals.

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