Fangda Partners‘ sizeable group has significant experience in corporate investigations, government enforcement matters (both administrative and criminal), compliance programmes and policies, and related contentious matters. The firm is also home to specialists in anti-bribery and corruption, cyber security, data protection, sanctions and export control, as well as environmental protection, advertising law, securities regulations, state secrets, unfair competition, and criminal matters. Splitting her time between Beijing, Hong Kong and Guangzhou, Kate Yin is an expert in government enforcement work, internal investigations and regulatory compliance; and the workload of Benjamin Miao in Shanghai also encompasses regulatory issues and investigations. Other mainland China names to note are Yanjun Zhuang, Derrick Zhao, Yingjie Kang and Lei Yang, along with Yujin Liu.
Regulatory/compliance: PRC firms in China
Fangda Partners
Responsables de la pratique:
Kate Yin
Autres avocats clés:
Benjamin Miao; Yanjun Zhuang; Derrick Zhao; Yingjie Kang; Lei Yang; Yujin Liu; Xilong Wang
Les références
‘Full-service compliance and investigations practice – reasonable and practical.’
‘The best external legal team around for compliance investigations.’
‘Has a deep understanding of the dynamics of industry compliance and regulation, and can provide clients with very practical and professional legal advice.’
King & Wood Mallesons
King & Wood Mallesons has an enviable market reputation for its expertise in transnational regulatory investigations and corporate compliance management. The practice covers an array of investigations, ranging from those conducted by US regulators under the US Foreign Corrupt Practices Act, along with investigations brought by multilateral development banks (MDBs), and Chinese administrative enforcement bodies and criminal prosecution authorities. The team is co-led by Beijing-based Wei Wu, a specialist in anti-commercial bribery, corporate compliance risk assessments, MDB investigations, compliance programmes, and corporate crisis management; and highly-rated compliance expert Harry Liu in Shanghai. Also in Beijing, Junfeng Chang has notable experience in compliance investigations, while Xiaodan Xu and Yuanyuan Zhu are other key team members. Han Yang departed the firm in November 2023.
Responsables de la pratique:
Wu Wei; Harry Liu
Autres avocats clés:
Junfeng Chang; Xiaodan Xu; Yuanyuan Zhu; Gan Yulai; Liu Yanjie; Zhang Shuang; Huang Huang
Les références
‘The team has rich experience in compliance matters, strong professional backgrounds, strong professional support capabilities, and strong response capabilities.’
‘In terms of billing, it focuses on long-term collaborative relationships and has a high level of flexibility.’
‘The regulatory and compliance team is very knowledgeable about industry risk points.’
Principaux clients
XCMG Construction Machinery Co
HNA Trust Management Co
Longxiang Group
Marriott International
China Broadcasting Network Co
Servier (Tianjin) Pharmaceutical Co
TBEA Co
Principaux dossiers
- Assisted TBEA Co with establishing a corporate compliance programme, in relation to its headquarters (as well as each branch and subsidiary).
- Assisted XCMG Construction Machinery Co with implementing a specialised compliance programme that comprehensively covers the client’s group headquarters, as well as over 60 subsidiaries in the US Europe, India, Russia (and other countries).
- Commissioned by HNA Trust Management Co to develop a compliance system that aligns with multifaceted regulatory requirements.
FenXun Partners
The ‘excellent team’ at FenXun Partners has notable experience in compliance-related internal and external investigations. The group’s expertise covers anti-bribery, fraud, conflicts of interest, advertising and pricing law, health and safety at work, and environmental protection. The practice also assists with compliance due diligence in both transactional and non-transactional contexts, along with regulatory issues, risk assessments, compliance programmes, cross-border work and enforcement issues. Clients also notably benefit from the firm’s joint operation with Baker McKenzie. Vivian Wu heads the firm’s investigations, compliance and ethics team in Beijing; and in Shanghai, ‘top expert’ Henry Chen is an expert in bribery, corruption, money laundering, unfair competition, customs, data protection, and cybersecurity. Chen also advises on employee misconduct, fraud and whistleblower allegations.
Responsables de la pratique:
Vivian Wu
Autres avocats clés:
Henry Chen; Kailin Wang; Claire Wu; Yiwei Sun; Shuting Liu
Les références
‘The team is extremely knowledgeable and experienced in this area, and it is able to deliver great results that go beyond clients’ expectations.’
‘It does not need many instructions, as many other firms do, and knows how to proceed, providing timely interim reports and adjusting as clients’ priorities shift.’
‘Communications with the team are very smooth.’
Global Law Office
Global Law Office covers the gamut of regulatory and compliance work, including risk assessments, compliance policies, reporting, training, investigations, and defence-side matters. In addition to assisting multinational and Chinese entities with compliance issues, the practice regularly assists academies, governmental bodies and state-owned companies with the education and certification of in-house and external compliance practitioners. In Shanghai, Alan Zhou is an expert in corporate investigations, anti-corruption and regulatory compliance; Lai Wang focuses on financial and duty crime, corporate criminal compliance, risk control, data compliance, anti-money laundering, cooperate compliance systems, and risk alert mechanisms; and Jacky Li assists with regulatory compliance and corporate and government investigations. Over in Beijing, Weiwei Gu is particularly focused on anti-bribery investigations.
Responsables de la pratique:
Alan Zhou; Weiwei Gu
Autres avocats clés:
Lai Wang; Jacky Li; Maggie Meng; Deming Zhao; Coco Fan; Kelly Cao; Xi Wang; Li Su; Jenny Chen; Kun Yin
Les références
‘Keen insights into industry risks and compliance trends – extensive experience in this field.’
Principaux clients
Chery Jaguar Land Rover
The Zeiss Group
AstraZeneca
GlaxoSmithKline China
Siemens
Abbott
Roche
Boehringer Ingelheim
CanSino Bio
Aspen Pharma
Fosun Pharma
Gensci
Geistlich
Shanghai Jet Express Co
Principaux dossiers
- Assisted with achieving ISO 37301 Compliance Management System Certification and ISO 37001 Anti-Bribery Management Systems Certification.
- Contributed to the setting up of the Medical Representatives Compliance Exam, initiated by RDPAC.
- Assisted Boehringer Ingelheim Co with several internal investigations.
Haiwen & Partners
Consistently sought out by multinational and domestic companies, Haiwen & Partners is experienced in anti-corruption, anti-fraud, conflicts of interest, data protection and antitrust. The practice also comprises experts in economic sanctions, export control, anti-money laundering, customs, and compliance-related dispute resolution. Heading up the regulatory team from Beijing, Jianyuan Yang, who is ‘great at solving difficult problems’, is an expert in anti-corruption, data compliance, internal investigations and due diligence. Also in Beijing, Dan Wu assists with a range of regulatory filings, her experience including a cybersecurity review for an overseas listing. Notable growth for the team includes the late 2023 recruitment of Shuaqi Yuan, a specialist in international trade and sanctions, from Perkins Coie LLP’s Washington DC office.
Responsables de la pratique:
Jianyuan Yang
Autres avocats clés:
Dan Wu; Shuaqi Yuan
Les références
‘Great insight into clients’ needs – a very professional and conscientious service.’
‘Rich experience in compliance supervision concerning drugs and medical devices, including but not limited to research and development, production and business operations.’
‘A lot of experience in the latest laws and regulations. Clients get very practical and effective legal opinions.’
Han Kun Law Offices
Han Kun Law Offices is known for assisting multinationals and foreign-invested businesses with regulatory compliance. The team also conducts internal reviews and investigations; its track record includes representing multinationals’ subsidiaries during PRC-related anti-bribery, Foreign Corrupt Practices Act (FCPA) and UK bribery investigations. Shanghai-based Michelle Gon is ‘a respected lawyer in the compliance market’; David Tang's wide-ranging practice includes corporate compliance and data protection; Weiheng Jia advises on anti-bribery, business ethics, unfair competition, and data security and protection; Jolie Yan advises on white-collar matters, investigations, anti-corruption, data security, and regulatory compliance; and Zhaojun (Sophie) Shi focuses on regulatory and governmental affairs, anti-bribery, FCPA issues, anti-monopoly, and related risk assessments and investigations. In Beijing, Chen Ma is a veteran antitrust practitioner.
Responsables de la pratique:
Chen Ma; Weiheng Jia
Autres avocats clés:
Michelle Gon; David Tang; Zhaojun (Sophie) Shi; Jolie Yan; Xinjie Li; Ying Huang; Yang Han
Les références
‘Their approach and delivery are always highly appreciated.’
‘Great quality and responsiveness.’
‘They have lawyers from different backgrounds, who can cover issues that are unique to certain industries. They also have rich experience in handling PRC regulatory work.’
Principaux clients
Siemens
American Express
Volkswagen
JunHe
With ‘outstanding expertise in compliance investigations’, JunHe’s regulatory and compliance practice covers cross-border data transfers, data privacy, and cybersecurity and information legislation. The team also assists with digitisation, environmental, and health and safety compliance. In Shanghai, Leon Liu acts in white-collar matters, along with government and internal investigations; Lei Wu's track record includes compliance investigations and commercial bribery cases; David Tang is an economic sanctions and export control specialist; and Lingyun He handles corporate investigations. Also in Shanghai, Carol Sun is ‘a trusted legal partner for clients’, in relation to cross-border investigations, white-collar crime, and China data security and national security compliance. Beijing-based Yingling Wei advises automotive, telecoms, pharmaceutical, medical devices and consumer product clients on antitrust compliance.
Responsables de la pratique:
David Tang; Yingling Wei; Leon Liu
Autres avocats clés:
Lei Wu; Lingyun He; Carol Sun; Jacky He; Carol Sun; Marissa Dong
Les références
‘Outstanding expertise in compliance investigations.’
‘Composed of senior lawyers who are well versed in regulatory laws and regulations. They not only provide appropriate legal advice, but also skillfully use digital tools and AI and other technical means to improve the efficiency and accuracy of compliance investigations, while ensuring that the investigation activities strictly comply with the laws and regulations.’
‘Carol Sun and her team maintain close communication with clients, share the latest compliance regulations in a timely manner, and provide customised risk management solutions based on the client’s corporate structure, so as to help the client seize market opportunities and maintain compliance.’
Principaux clients
China Baowu Steel Group Corporation
Shanghai Baosteel Packaging Co
Baowu Group Finance Co
Baowu Resources Co
Shanghai Baosight Software Co
Zhong Lun Law Firm
‘A go-to law firm for PRC-related matters’, Zhong Lun Law Firm is routinely mandated to establish compliance systems. It also assists with multi-jurisdictional investigations, and advises on sanctions imposed by multilateral financial institutions. In addition to advising regulatory bodies, the practice acts for central enterprises, multinationals and large private companies from the construction aviation, energy, food, pharmaceutical and natural resources sectors. In Beijing, Xiangwen Liu is experienced in regulatory compliance; Xuan Jang is ‘incredibly smart’; and Baosheng Zhang, Ruixuan Li, Jinshu Zhu and Qiang Xiao all specialise in securities compliance. Over in Shanghai, Jim Qiu acts for pharmaceutical, medical device and online medical businesses; and Gary Gao is ‘superb’. Shenzhen-based Eric Yan advises on the establishment of compliance management systems.
Responsables de la pratique:
Xiangwen Liu; Gary Gao
Autres avocats clés:
Xuan Jang; Baosheng Zhang; Ruixuan Li; Jinshu Zhu; Qiang Xiao; Jim Qiu; Eric Yan; Changyu Fu; Yuru Zuo
Les références
‘Well-known large firm, strong levels of professionalism, rich resources, good service, and reasonable fees.’
‘Superb business sense, rich experience, timely feedback and reasonable fees.’
‘Zhong Lun is a go-to law firm for PRC-related matters, in particular regulatory matters and related litigation.’
Principaux clients
Softbank Group
Lightspeed China Partners
Nexteer Automotive Group
GoodCorporation
Argo Biopharma
Jin Jiang International (Holdings) Co
Jin Jiang Hotels
PowerCell Group
Bridgepoint Investment
Evaluserve
Jiangsu PetroChina Kunlun Liquefied Gas Co
China National Offshore Oil Corporation
China Huadian Engineering Co
Inner Mongolia Mengniu Dairy Group Co
China Energy Saving Emission Reduction Co
Beijing Equity Investment Development Management Co
Beijing ShunLong Private Debt Investment Fund Management Co
Beijing Jingguorui Equity Investment Fund Management Co
Shenzhen Kunpeng Equity Investment Management Co
Beijing E-town International Investment and Development Co
Beijing Urban Construction Group Co
MSD China Holding Co
Anheuser-Busch InBev China Co
Eastman Chemical (China) Co
Dassault Systems (Shanghai) IT Co
Jiangsu Asieris Pharmaceutical Technology Co
Shenzhen Gas Group Co
Shenzhen Zhenye (Group) Co
Shenzhen Building Materials Trading Group Co
Shenzhen Gas Group Co (Guangming Branch)
China Securities Co
Dongxing Securities Co
Hainan Dadonghai Tourism Center Group Co
Misho Ecology & Landscape Co
Qibu Corporation
Principaux dossiers
- Assisted Jin Jiang International and Jin Jiang Hotels with establishing a comprehensive compliance system.
- Assisted China National Offshore Oil Corporation with improving its compliance management system.
- Assisted infrastructure companies with successfully responding to investigations by the European Anti-Fraud Office and the European Investment Bank (EIB) into misconduct in multiple EIB-financed projects across several countries.
DaHui Lawyers
DaHui Lawyers' practice covers cross-border and domestic regulatory issues, liaising with government agencies, obtaining regulatory approvals, and developing strategies to overcome regulatory obstacles. The team was recently notably active in company law and data protection matters, as well as regulatory investigations. Beijing and Shanghai-based Richard Ma is a TMT specialist; and in Shanghai, Joanna Jiang advises on market entry and regulatory matters; Cloud Li assists with employment and compliance issues; and Zhengwei Yang's practice covers compliance and investigations.
Responsables de la pratique:
Richard Ma
Autres avocats clés:
Joanna Jiang; Cloud Li; Zhengwei Yang; Jie Tong
Principaux clients
Airbnb
Alibaba Group
Alibaba Pics
Ali Sports
Youku
Allbirds
Altair Semiconductor
Altek
Amador Bioscience
AMap
Amazon
Ant Group
Arrow Electronics
Biyi
BlephEx
British Medical Journal
Boeing
Brookfield Logistics
Cactus Communications
Cainiao
CBS Corporation
CEEC
Cellomics Bio
China International Capital Corporation
China World Trade Center
Cirium (Flight Global)
Cloudflare
Comcast Communications
Daqo New Energy
Discovery
Discovery Communications
Eton College
Evernote Corporation
Yinxiang Biji (Shanghai) Technology Co
Freewheel
Genecast Biotechnology
Giuseppe Zanotti
Hannover Fairs
HEBE Beauty
Hewlett Packard Enterprise
Improbable World
Inspirock
Intel
ITE
J&T Global Express
JHD/Yellow River
Jones Lang LaSalle
Joyo Technology
Kwai (KuaiShou)
LexisNexis Legal Professional & Risk Solutions
LG Electronics
Loftware
Magic Tree Productions
Mattel
Messe München Group
Microsoft Corporation
Modern Classics
Moutai
Narwal
NBA
NBC Universal
Netflix
Newegg
O’Reilly Media
Peterson Control Union
Power China
Princeton University Press
Qi’anxin Technology
Reed Exhibitions
RELX Group
Research Square (AJE)
Samsung Electronics
Sequoia CBC Cross-Border Digital Industry Fund
Siam Cement Group
Signify
Simon & Schuster
SingEx Exhibitions Pte
SPARK Microsystems
Springer Nature
SQM Industrial
The Economist
Tiger Brokers
Toshiba Mitsubishi Electrics
Trustana
UTA
Viva Ventures
Vivo
Vonage
William Morris
World Gold Council
WorldQuant
Xinyuan Real Estate
YMTC
Yuanben BioTech
Zaihui Network Technologies
Zhijie Yuangang International Supply Chain Technologies
Principaux dossiers
- Advising a US-listed international company on introducing highly- regulated web infrastructure and security products into China.
- Assisting a world-renowned publication and analytics business with a new regulatory rule regarding its China products.
- Assisting an international aviation giant with revamping multiple joint ventures in China, in relation to major changes in PRC company law.
Dacheng
Dacheng houses experts in anti-bribery law and anti-fraud investigations, as well as export control, economic sanctions, cybersecurity, data governance, and compliance management systems and auditing. In Beijing, Liping Yan is director of the firm’s corporate compliance legal service centre; and Kaiming Cai‘s wide-ranging practice includes data compliance. Over in Shanghai Litong Chen is a former Asia-Pacific compliance director of Ford Motor (China); while Ma Hongwei is a key member of the compliance and risk management practice group.
Responsables de la pratique:
Liping Yan
Autres avocats clés:
Kaiming Cai; Litong Chen; Ma Hongwei; Donghui Ruan
Les références
‘One of the few teams that specialises in providing integrated legal services in civil, administrative and criminal matters.’
‘Clients are deeply impressed by the efficient work attitude, outstanding professional ability and innovative thinking.’
’Strong ability to handle complex matters and excellent feedback speed. Can quickly review a large amount of case files, analyse financial data and formulate case-handling plans in a short period of time, demonstrating their strong organisational response capabilities when facing complex situations.’
Principaux clients
Shenzhen Tencent Computer Systems Co
CCPIT
Beijing Zitiao Network Technology Co
Nanjing Red Sun Co
Guangzhou Shiyuan Electronic Technology Company
Geely Automobile Group Co
Semiconductor Manufacturing International Corporation
China General Nuclear Power Corporation
China General Nuclear Power Group
China Energy Construction Corporation
Aluminum electric Jinhai Co
Guangdong Environmental Protection Group Co
Principaux dossiers
- Assisting Aluminum & Power Jinhai Co and Aluminum Electric Jinhai Co with its internal control mechanisms.
- Assisted Guangzhou Shiyuan Electronic Technology Co with export control and economic sanctions compliance.
- Assisting Geely Automobile Holding (Hangzhou) Co with export control and economic sanctions compliance management.
Jingtian & Gongcheng
Jingtian & Gongcheng's compliance practice focuses on corporate investigations, anti-corruption, fraud and commercial bribery. Heading up the team from Guangzhou, Guanghui Zhu specialises in corporate investigations and anti-corruption. In Beijing, Siyuan Liu assists with securities-related compliance; and Qingdong Fan is a corporate investigations and anti-corruption expert. Another name to note for Beijing is Feng Zhao, whose practice covers securities compliance, anti-bribery, internal investigations, litigation and criminal compliance; while in Shanghai, Shiqi Sun ‘proposes creative ideas and response strategies’.
Responsables de la pratique:
Guanghui Zhu
Autres avocats clés:
Siyuan Liu; Qingdong Fan; Feng Zhao; Shiqi Sun
Les références
‘Great firm, network and work product.’
‘With their profound legal skills and excellent practical legal skills, they provide professional analysis, opinions and suggestions.’
‘They maintain good communication levels and information synchronisation with clients, and they efficiently reply to the questions and needs raised.’
Principaux clients
CITIC Securities Co
Zhong De Securities Co
Aerospace Communications Holdings Co
Kangde Xin Composite Material Group Co
Peking University Founder Group Co
Guangdong Guangzhou Daily Media Co
Luckin Coffee Group Co
Shanghai Jinglin Asset Management Co
State Grid Yingda Group
Harvest Fund Management
Principaux dossiers
- Successfully acted for Zhong De Securities Co in a securities fraud litigation.
- Assisted Kangde Xin Composite Material Group Co with its administrative investigation and securities fraud litigation.
- Defended Shanghai DZH’s directors, supervisors and executives against a recourse action brought by China Securities Investor Services Center to recover loss for misrepresentation in a previous administrative procedure.
Llinks Law Offices
Llinks Law Offices fields specialists in anti-corruption, cybersecurity, data protection, antitrust, and trade control and investment regulation. The practice also assists with the regulatory side to employment law, IP and environmental protection. In Shanghai, David Pan's track record includes advising pharmaceutical, healthcare, education, tourism, advanced manufacturing and retail clients on anti-corruption compliance programmes in China; and Patrick Gu assists with labour and employment-related matters, such as anti-bribery, anti-corruption, trade secrets and white-collar crime. Nigel Zhu is another experienced practitioner.
Responsables de la pratique:
David Pan
Autres avocats clés:
Patrick Gu; Nigel Zhu
Principaux clients
IDEXX Laboratories
SKF Bearings Shanghai
Essilor (China) Investment Co
Venator Materials
Ansell
Ingersoll Rand (China) Investment Co
Bracco Imaging Medical Technologies (Shanghai) Co
Principaux dossiers
- Assisted Ingersoll Rand with an anti-fraud investigation.
- Assisted Bracco with an anti-bribery investigation.
- Assisted Shanghai Municipal Commission of Commerce and Shanghai Pudong Chamber of International Commerce, in relation to compliance check-ups for Chinese enterprises going global.
Topcom China Law Offices
Sector specialisms for Topcom China Law Offices range from advanced manufacturing, food and agricultural products, to healthcare, industrial automation, automotive and e-commerce. The practice’s scope of expertise covers compliance governance, import and export trade compliance, anti-bribery, anti-corruption, government investigations, litigation, white-collar crime, and cross-border data transfer. In Shanghai, the track record of James Jiang, a February 2023 recruit from Yuanda China Law Offices, includes high-profile government and corporate investigations. Other key compliance figures are Feng Cheng and Joyce Xie.
Responsables de la pratique:
James Jiang
Autres avocats clés:
Feng Cheng; Joyce Xie; Zehan Li
Les références
‘The team is flexible and handles cases in a diversified manner and according to clients’ business needs, and it stays in close communication with the local compliance network in Shanghai.’
‘The lawyers understand the legal needs of clients’ business and provide prompt and professional services.’
‘Extensive experience in handling compliance cases.’
Principaux dossiers
- Provided compliance consulting and internal investigation services, in relation to the protection of a domestic Hi-Tech company’s trade secrets.
- Advised a domestic industrial automation company on export control and data exit issues.
- Provides daily legal and compliance counsel services to an ophthalmic pharmaceutical company, including preparing compliance opinions in relation to the business restructuring of its subsidiary.
Yuanda China Law Offices
Yuanda China Law Offices is experienced in the compliance aspects of employment, white-collar crime, the Foreign Corrupt Practices Act, and cross-border government investigations. Through its exclusive strategic alliance with US-based international law firm Winston & Strawn LLP, the team’s expertise extends to foreign regulatory regimes impacting Chinese and China-based corporations with multi-jurisdictional business interests. In Shanghai, John Huang's broad practice includes regulatory compliance; while Andy Pan's sector expertise encompasses clean energy vehicles, semiconductors, healthcare, telecoms, entertainment, and consumer products.
Responsables de la pratique:
John Huang; Andy Pan
Autres avocats clés:
Kai Zhan; Leo Zhu; Dora You
Les références
‘Strengths – its strategic alliance with Winston & Strawn in the United States, assisting Chinese companies and multinational corporations operating in China with the complex legal and regulatory environments at home and abroad.’
’Andy Pan – professional, good service quality and timely message processing.’
Principaux clients
Volvo Cars (China) Investment Co
China Electrical Equipment Group Co
Hangzhou Hutu Technology Co
Principaux dossiers
- Advised Volvo Cars (China) Investment Co on compliance with PRC data protection laws and regulations.
- Assisted China Electrical Equipment Group Co with completing the establishment of an overseas compliance framework.
- Assisted Hangzhou Hutu Technology Co with analysing potential legal risks and providing compliance advice.
Zhao Sheng Law Firm
Zhao Sheng Law Firm is notably experienced in financial markets regulatory work, as well as the regulatory side to financial services-related transactions. For matters involving multiple jurisdictions, clients further benefit from the firm’s joint operation office with Linklaters. Richard Gu leads the team from Shanghai, where Colette Pan specialises in the regulation of mainland China’s financial markets and financial services; and Ying Zhou (promoted to partner in November 2023) is structured finance and derivatives head. Eric Liu recently departed the firm.
Responsables de la pratique:
Richard Gu
Autres avocats clés:
Colette Pan; Ying Zhou; Hansen Ji; Ningying Bao
Les références
‘Deep understanding of laws and regulations.’
‘Rich experience, especially in the supervision of financial institutions in relation to foreign capital.’
Principaux clients
Citibank (Hong Kong)
Hong Kong Exchange and Clearing
Harvest Global Investments
GF Securities (Hong Kong) Brokerage
UBS Fund Distribution (Shenzhen) Co
Asia Securities Industry & Financial Markets Association
Principaux dossiers
- Assisted Microsoft with obtaining unconditional clearance in China for its $70bn proposed acquisition of Activision Blizzard.
- Advised Harvest Global Investments on the successful issuance of its tokenised fund in Hong Kong.
- Advised Citi on the sale of its mortgage loan assets and credit cards receivables, and the $3.6bn sale of its onshore consumer wealth portfolio in China.