This July 28 Law360 article by McGuireWoods lawyers Alex Brackett and Ryan Bonistalli discusses recent enforcement action in China that demonstrates why anti-corruption compliance efforts should not focus exclusively on interactions with government officials. Commercial bribery also can result in liability under the Foreign Corrupt Practices Act. Subscribers can read the full text of the Law360 article at The article was based on a July 21 Subject to Inquiry blog post by Alex and Ryan that was published under the same title at

Originally published by Law360.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.