中国贿赂犯罪立法与《联合国反腐败公约》之比较
A Comparison between China’s Criminal Legislation on Crime of Bribery and the “United Nations’Convention of Anti-corruption”
摘要
中国贿赂犯罪刑事立法与《联合国反腐败公约》在行贿方式、行贿罪的目的要件等的规定上具有契合性,在行贿人的刑事责任、贿赂的内容、外国公职人员或者国际公共组织官员贿赂犯罪的规定等问题上具有差异性。 The criminal legislation on the crime of bribery in China is accordance with the “United Nations'(UN's) convention of anti-corruption"when concerning the forms, the elements and the intention of bribery. But as for the criminal responsibilities, the subject matter, the regulations on it for foreign public officials or international public organizations' officials, China's criminal legislation on bribery is different from UN's convention.