The DOJ’s indictment against two former executives of the Chinese subsidiary of Herbalife showcases the challenges, in some measure, that multilevel marketing companies can experience in China as they seek to navigate legal requirements there. In November 2019, the DOJ charged Yanliang “Jerry” Li, the former head and managing director of the subsidiary, and Hongwei “Mary” Yang, former head of external affairs at the subsidiary, with one count of conspiracy to violate the FCPA. Li also faces obstruction of justice charges. Both defendants are citizens of China. See “Revisiting the China Initiative: Will the Focus on FCPA Prosecutions of Chinese Companies Produce Results?” (Jul. 10, 2019).