While bribery is designated as a criminal offense in most jurisdictions, the enforcement of anti-bribery laws in the corporate context is far from satisfactory. The weak enforcement can be mainly attributed to the practical challenges of doing so. Benefiting from deferred prosecution agreements (DPAs), the U.S., UK and French authorities have significantly ramped up their anti-bribery enforcement and encouraged corporate self-policing activities. Inspired by the foreign DPA developments, China’s prosecutorial authorities have been actively promoting the compliance non-prosecution program (CNP) since 2020. Introduced amid the Covid-19 pandemic and the ever-intensive U.S.-China trade conflicts, the CNP aims to mitigate the adverse economic implications of corporate criminal enforcement and foster corporate compliance.Combining legal doctrinal research, comparative research and insights from the law and economics literature, this thesis provides an overview of the DPA regimes in the U.S., UK and France and the CNP in China. It analyzes the advantages and weakness of the DPA programs in the three jurisdictions, aiming to draw lessons for developing the Chinese version of DPA program to address corporate bribery. Meanwhile, it also identifies the reasons for the inactive role played by the corporations in China’s anti-bribery movement and the challenges caused for the authorities in the anti-bribery enforcement. It is proposed that a Chinese version of DPA program be established based on the existing CNP to resolve corporate bribery cases. When designing and applying the Chinese version of DPA program and complementary regimes, special attention should be paid to deterrence, rehabilitation, and individual accountability.<br/
