China published draft revisions to its corporate overseas antitrust compliance
guidelines for public comment, aimed at helping firms track foreign enforcement
trends. The draft consolidates recent overseas antitrust legislative and
enforcement changes and embeds foreign enforcers' digital‑economy focus into
sections on cartels, abuse of dominance and merger control; it clarifies recent
merger filing thresholds in jurisdictions including the EU, US and Germany,
flags foreign investment security reviews and foreign subsidy review regimes as
material risks, and—responding to rising cross‑border antitrust litigation—adds
coverage of major jurisdictions' rules on private civil suits alongside
administrative fines and criminal liability.
