With the official implementation of the “Judicial Interpretation (II) on Embezzlement and Bribery,” regulatory oversight in the food and drug industry has been comprehensively tightened. The judicial standards for determining commercial bribery and corporate occupational crimes have undergone significant adjustments, marking the entry of industry compliance and risk management into a new phase characterized by stricter and more rigorous enforcement. To assist food and drug companies in accurately adapting to the new regulations, mitigating criminal risks, and establishing compliance systems, the “Seminar on Criminal Risk Prevention and Control for Food and Drug Companies Under the New Judicial Interpretation on Embezzlement and Bribery” was successfully held on July 12, 2026, in the lecture hall of the Nanjing Bar Association. The event was organized by the Nanjing Bar Association and co-hosted by the Criminal Risk Prevention and Control Committee of the Nanjing Bar Association, the King&Capital Environmental, Food, and Drug Intellectual Property Law Research Center, and Beijing King&Capital (Nanjing) Law Firm.

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Event Venue | Attorney Zhu He Presiding

The event was presided over by Attorney Zhu He of King&Capital’s Nanjing branch. Ding Jiajian, Deputy Secretary-General of the Nanjing Bar Association, delivered opening remarks. All members of the Nanjing Bar Association’s Criminal Risk Prevention and Control Committee, representatives from food and drug enterprises, and numerous attorneys attended the event to exchange insights and explore new pathways for compliance and risk management.

01 Opening Remarks

Focusing on New Industry Policies, Charting the Course for Compliance-Driven Development

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Event Venue | Deputy Secretary-General Ding Jiajian Delivers Opening Remarks

At the outset of the event, Deputy Secretary-General Ding Jiajian delivered opening remarks. He provided an accurate assessment of the new regulatory landscape for the food and pharmaceutical industry under the new regulations, clarifying that the seminar aimed to empower lawyers to advance their professional expertise, build a bridge of communication between law firms and enterprises, and safeguard the high-quality development of the local food and pharmaceutical industry. He also urged practicing attorneys to use “research” as a foundation to deepen expertise in specialized fields, prioritize “prevention” in legal services, and focus on “implementation” to put compliance solutions into practice, thereby serving as guardians of the rule of law in the food and drug industry.

02 King&Capital Think Tank’s In-Depth Expertise

Focusing on Pain Points of the New Regulations, Delivering Practical Compliance Insights

As the core organizer of this event, the expert team from King&Capital Law Firm’s Think Tank delivered substantial insights centered on the key points of the new regulations and practical challenges in the industry, fully demonstrating their deep professional expertise.

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Event Scene | Attorney Zhang Sijia

Attorney Zhang Sijia, Deputy Director and Secretary-General of the King&Capital Law Firm’s Environmental, Food, and Pharmaceutical Law Research Center, delivered a presentation titled “Criminal Risks and Compliance Pathways for Pharmaceutical Companies Under New Anti-Corruption Regulations.” Beginning with big data on corporate crime in 2025, she addressed the “Current State of Corporate Crime in China” and the “New Anti-Corruption Regulatory Framework and Trends in the Pharmaceutical Sector,” systematically outlining the legal framework for crimes related to embezzlement and bribery in the pharmaceutical industry, provided an in-depth analysis of the core provisions of “Interpretation (II)” relevant to pharmaceutical companies, and offered actionable compliance guidelines for nine high-risk business scenarios—including academic visits, business hospitality, consulting services, outsourced services, discounts and commissions, donations and sponsorships, equipment placements, clinical research, and retail outlets—concluding with a discussion on restructuring the criminal compliance system to transition from formal compliance to substantive compliance.

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Event Venue | Attorney Tang Jianbin

Attorney Tang Jianbin, Director of the King&Capital Environmental, Food, and Pharmaceutical Intellectual Property Law Research Center, delivered a presentation titled “A Study on the Distinguishing Criteria for Corporate Bribery Crimes in the Pharmaceutical Industry from the Dual Dimensions of Corporate Will and Attribution of Interests.” Beginning with the background and core provisions of “Interpretation (II),” he identified three major shifts in the determination of corporate crimes: the substantivization of determination standards, the clarification of liable entities, and the centralization of interest attribution. He systematically explained the dual-dimensional assessment criteria of “substantive review of corporate intent” and “determination of corporate benefit attribution.” Drawing on typical cases such as the false academic promotion case involving a pharmaceutical company in Shandong, he clarified the boundaries between corporate and individual liability in pharmaceutical bribery and offered compliance insights, including the need to abandon formalism, strengthen mid-level oversight, conduct substantive reviews of expenses, and link performance evaluations to compliance.

03 Expert Collaboration and Empowerment

Multidimensional Risk Analysis to Build a Comprehensive Risk Control System

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Event Venue | Attorney Tian Zhongwei

Attorney Tian Zhongwei, Deputy Director of the Criminal Risk Prevention and Control Committee of the Nanjing Bar Association and Partner at Grandall Law Firm (Nanjing), delivered a presentation titled “From Kickbacks to Red Lines: The Substantive Impact of Judicial Interpretation No. 2 on the Healthcare Industry.” Starting from the systemic adjustments introduced by “Interpretation No. 2,” he analyzed the criminal legal framework it has established for the healthcare industry—characterized by “indiscriminate coverage and targeted crackdowns”— He focused on five major impacts: the sharp rise in risks associated with crimes involving non-public office holders; the “piercing the corporate veil” approach to determining corporate bribery; the criteria for establishing independent criminal liability for corporate bribery; the independent prosecution of intermediary bribery; and the special protection afforded to medical insurance funds as “specific funds and property.” He also proposed response strategies, including “piercing the corporate veil” compliance audits, restructuring business models, and contingency plans for the transition from administrative to criminal proceedings.

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Event Venue | Attorney Liu Ruxiang

Attorney Liu Ruxiang, Chair of the Criminal Risk Prevention and Control Committee of the Nanjing Bar Association and a member of the Criminal Law Committee of the All-China Lawyers Association, delivered a presentation titled “Analysis of High-Frequency Criminal Risk Points in the Pharmaceutical Industry Under the New Judicial Interpretations on Embezzlement and Bribery.” Starting with the “Interpretation (II)” and accompanying new regulatory provisions, systematically reviewed high-frequency criminal charges and typical cases in the pharmaceutical industry. She also provided practical and actionable prevention recommendations focused on building compliance “firewalls,” including crisis early warning systems, substantive lists of decision-making authorities, “look-through” reviews of beneficial ownership, and corresponding standards for compliance documentation.

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Event Venue | Attorney Yang Dong

Attorney Yang Dong, Chair of the Criminal Law Committee of the Jiangsu Provincial Bar Association and partner at Jiangsu Sanfa Law Firm, delivered a presentation titled “Prevention of Occupational Crimes and Compliance System Development in Pharmaceutical Companies,” Beginning with the evolution of anti-corruption efforts in the healthcare sector from “cracking down on individual cases” to “systematic governance,” he conducted an in-depth analysis of criminal risk points for pharmaceutical companies in three major areas: commercial bribery, corporate bribery, and internal occupational crimes. He also proposed a systematic prevention and control strategy for a compliance “firewall” based on a three-pronged approach encompassing institutional development, operational mechanisms, and capacity building.

04 Seminar Concludes Successfully

Packed with Practical Insights, Receiving Consensus Praise from the Industry

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Group photo of attendees

The entire seminar featured a step-by-step progression of content closely aligned with practical applications, comprehensively covering key topics such as interpretation of new regulations, determination of criminal charges, scenario-based risk control, and system development. It helped participating lawyers and corporate representatives clarify compliance red lines and risk control priorities under the new regulations. On-site participants unanimously praised the content for being highly substantive and practical, effectively addressing the practical challenges enterprises face in maintaining compliance.

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The successful hosting of this seminar fully demonstrates the deep expertise and professional capabilities of the King&Capital Environmental, Food, Drug, and Intellectual Property Law Research Center and the King&Capital Nanjing Branch in the fields of environmental, food, drug, and intellectual property compliance and criminal risk management. King&Capital Environmental, Food, Drug, and Intellectual Property Law Research Center, in collaboration with the Kyoto Nanjing Branch, will continue to deepen its expertise in the specialized field of food and drug legal services. Leveraging its dedicated think tank platform, the center will remain focused on the challenges of implementing new industry regulations and addressing corporate compliance pain points, while regularly conducting professional seminars and providing empowerment services for law firms and enterprises. Through specialized legal services, the center aims to help food and drug companies strictly adhere to compliance standards and achieve steady, high-quality development.