For years, China has featured prominently in the US Department of Justice's investigations under the Foreign Corrupt Practices Act, or FCPA. That's not news to the readers of this blog, who can refresh their memories here, here and definitely here. But as a colleague recently reminded me, there is a big difference between settling an FCPA case, and actually having to investigate it—especially in China. This is a distinction that too few lawyers appreciate, but they should.

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Originally published by China Law Blog, April 10th, 2015

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