China Drafts Cross-Border Corruption Law-Critical-Mineral Supply Chains Face a New Compliance Fault Line

Highlights

• China's draft Anti-Cross-Border Corruption Law covers Chinese firms abroad, foreign firms in China, and conduct involving Chinese officials or state entities.
• Article 26 could bar foreign entities from conducting law-enforcement activities in China without approval, creating conflicts with U.S. FCPA and sanctions enforcement.
• Rare earth supply chains involving state-owned enterprises, joint ventures, and government permits face heightened jurisdictional compliance risk.
• The draft includes potential countermeasures if Beijing views foreign anti-corruption actions against Chinese entities as discriminatory.
• Legal jurisdiction is emerging as a new supply-chain risk variable for critical-mineral investors alongside tariffs and export controls.