Not really. You at least have to build up your guanxi before the violations occur (or brought up as a problem), once it happens, it’s too late. At anyrate, the FCPA has to be followed by American citizens as well as companies (other western companies have similar acts), so it isn’t really an option.

My point is, unless you are Chinese working for a Chinese company, don’t try to be edgy in China, follow both written and unwritten rules. Foreigners are great chickens to kill to scare the monkeys, as the Chinese idiom goes.

Meh, I often saw people ignore FCPA or find ways around it when I worked in China. Really, having your 51% JV partner be someone well connected with the Party was pretty much a guarantee of success. Granted, this was a decade or so ago.