Research on the Formulation of China's "Anti-Cross-Border Corruption Law" from a Comparative Law Perspective

This paper systematically examines the formulation path for China's Anti-Cross-Border Corruption Law from a comparative law perspective. It analyzes the core provisions and dual enforcement mechanisms of the US Foreign Corrupt Practices Act (FCPA), the commercial organization "failure to prevent bribery" liability model under the UK Bribery Act 2010, and the five core mechanisms (prevention, criminalization/law enforcement, international cooperation, asset recovery, monitoring) established by the UN Convention against Corruption (UNCAC), distilling commonalities and national characteristics in international cross-border corruption governance. The research identifies core dilemmas in China's current foreign-related anti-corruption legal system, including the absence of specialized legislation, fragmented and inadequate preventive measures, and insufficient international applicability of rules, necessitating urgent enactment of a dedicated law. Simultaneously, by integrating international conventions with Chinese wisdom, it will demonstrate China's responsible major country image. Actively sharing legislative experiences (e.g., "prevention priority") and participating in international rule negotiations will promote building a fairer, more inclusive new global anti-corruption order, significantly enhancing China's discourse power in international rule of law