China Center Quick Note: The AML Battleground - Looking Behind and Beyond the Current Regulatory Salvo

China’s National Development and Reform Commission (NDRC) has undertaken a series of aggressive and continually expanding anti-monopoly investigations of foreign invested commercial entities, manufacturers, technology providers, and service providers. The campaign appears on track to reach every commercial and industrial sector where foreign investors hold a material market share--a tsunami ripping through the foreign investment community. While the trend is undeniable, what is motivating it is not completely clear, although enough cases have gone through the process of investigation and remediation that it is possible to distill some informed insights.