An FCPA First*
Foreign Corrupt Practices Act enforcement actions against a company based on the conduct of a Chinese subsidiary are numerous (including instances in which the Chinese subsidiary is part of the resolution process).
FCPA enforcement actions against Chinese companies for violations of the FCPA’s books and records and internal controls provisions outside the context of foreign bribery (so-called non-FCPA, FCPA enforcement actions) have occurred. (See here, here and here for instance).
The FCPA enforcement action earlier this week involving BIT Mining (500.com) is believed to be the first FCPA enforcement action in history to involve a “Chinese issuer.”
Well, sort of.*
At least as close to a “Chinese issuer” “resolving” an FCPA enforcement action without technically a “Chinese issuer” “resolving” an FCPA enforcement action.