The FCPA Implications of China’s Plan to Consolidate State-Owned Enterprises

March 31, 2015

Legal media – Law360 and Main Justice – ran an article that originally published as a March 23 blog post by McGuireWoods attorneys Ryan Bonistalli and Alex Brackett. The article, which published under the same title as that of the original post, addresses “Made in China 2025,” China’s plan to restructure and consolidate its state-owned enterprises to bolster their position in the international marketplace. Specifically, the authors discuss the definition of “foreign official” under the U.S. Foreign Corrupt Practices Act, and related concerns for companies doing business with Chinese companies. Subscribers can read the full text of these articles at and The original post also is available on Subject to Inquiry, a blog maintained and written by McGuireWoods’ Government Regulatory and Criminal Investigations group of attorneys.