Today’s guest post is from Eric Carlson. Carlson is a Shanghai-based partner of Covington & Burling LLP. He specializes in anti-corruption compliance and internal investigations, with a particular focus on China and other regions of Asia. He speaks Mandarin and Cantonese and can be contacted here.
In recent years, some 17 settled FCPA enforcement actions involved, in whole or in part, allegations of improper travel benefits to Chinese citizens, often involving leisure travel to the United States.
This post outlines travel restrictions imposed by the Chinese government on its citizens and how companies may inadvertently facilitate leisure travel through visa invitation letters.