Corruption poses a constant risk to companies operating in China, but the nature of that risk is always shifting. Creative ways to create slush funds that can be used for bribery proliferate in China – travel agents, marketing companies and distributors have all been involved in funneling corrupt funds to foreign officials on behalf of businesses. In that environment, a company must have a dynamic and comprehensive compliance program. The Anti-Corruption Report, Paul Hastings and EY recently hosted a roundtable discussion about how companies can address and uncover new corruption issues in China while continuously monitoring old issues. The panel was moderated by the Anti-Corruption Report’s Editor-in-Chief, Nicole Di Schino. The panelists, all recognized experts in Chinese anti-corruption, included: Nat Edmonds, a Paul Hastings partner and former FCPA prosecutor; Ananda Martin, a partner in Paul Hastings’ Shanghai office; and John Auerbach, a partner and former Greater China managing partner in EY’s fraud investigation and dispute services group. This article summarizes the highlights of the panel discussion. For more insight from these experts, see “The Emperor Is Far Away: The Evolving Nature of Third-Party Risk in China
” (Sep. 9, 2015); and “Responding to China’s Aggressive Anti-Corruption Enforcement
” (Sep. 23, 2015).