On October 11, 2024, the Chinese State Administration for Market Regulation (SAMR, 国家市场监督管理总局) issued the Draft Compliance Guidelines for Healthcare Companies to Prevent Commercial Bribery Risks (the Draft Guidelines, 医药企业防范商业贿赂风险合规指引). These Draft Guidelines were published for public comment, due by Sunday, October 20, 2024. While China’s public comment system is still developing, the Draft Guidelines provide valuable insight into regulators’ views and expectations. We have prepared informal translations of the Draft Guidelines and their related Drafting Statement which provides additional background.

We believe these Draft Guidelines, once effective, will play a vital role in the development of compliance programs for China’s healthcare companies. For questions on this or any other subject, please reach out to the authors or any of their colleagues in Arnold & Porter’s White Collar Defense & Investigations practice group.

Read our Advisory for an overview of the Draft Guidelines, including informal English translations of the Draft Guidelines and their related Drafting Statement, which provides additional background.