Editor's Note: The issuance and deduction of VAT special invoices are necessary matters for the production and operation of most enterprises. VAT invoices, as important legal documents for VAT input deduction, are the basis for the normal operation of the VAT chain and the realization of national tax collection. False invoicing has not only damaged the order of invoice management, but also caused the loss of national tax, and has become the key target of tax, public security and other departments for a long time. In the recent Supreme People's Court, the Supreme People's Procuratorate tax-related crimes judicial interpretations and typical cases of the press conference, the Ministry of Public Security, Economic Crime Investigation Bureau, deputy director of the first level inspector Wu Di pointed out that in the past five years, the procuratorial organs to accept the examination and prosecution of cases of jeopardizing the administration of tax collection, the crime of fraudulent opening of special invoices for value-added tax accounted for about 80%. Wu Di also pointed out that precious metals, agricultural products, waste materials and other industries are the high incidence of fraudulent tax crimes in the field of renewable resources industry, for example, because of the inherent tax dilemma, renewable resources industry business model construction and invoicing the legitimacy of the existence of a number of disputes, the problem of false invoicing is prominent. This time, the judicial interpretation of the two high courts has made more changes to the crime of false invoicing of VAT and sentencing, and enterprises should pay attention to the changes in the risk of false invoicing brought by the judicial interpretation, adjust the business model in time and do a good job in compliance management. Based on the author's continuous research and agency experience in the field of false invoicing and the resources recycling industry, the author discusses the important revised clauses of the crime of false VAT invoices in the judicial interpretation of the two high courts and analyzes the changes and impacts on the enterprises in the resources recycling industry for the readers' reference.

The resources recycling industry has long been a key area of multi-departmental regulation due to the frequent problem of false starts

The Inspection Bureau of the State Administration of Taxation pointed out in its interpretation of the Opinions on Further Deepening the Reform of Tax Collection and Administration that local tax authorities should take tax risk as the guide, take "double random and one open" as the basic method, and appropriately increase the ratio of random inspection and carry out random inspection in an orderly manner for the key areas where the problem of tax evasion occurs, so as to accurately implement the tax supervision and crack down on tax-related illegal acts. In order to combat tax-related violations, the acquisition and utilization of waste materials is one of the key areas to be combated.

In the recent two high tax-related crimes judicial interpretation and typical cases of the press conference, the Ministry of Public Security, Economic Crime Investigation Bureau, deputy director of the first level inspector Wu Di pointed out that "the new industry, industry tax evasion problems are prominent. Precious metals, agricultural products, waste materials, electronic products, petrochemicals, coal and other industries are still the high incidence of fraudulent tax crimes." Resources recycling industry why the problem of false opening is frequent, the mode of operation of the industry is the key-

In order to solve the problem that downstream enterprises cannot obtain VAT invoices for waste materials purchased from the source retailers, the Ministry of Finance and the State Administration of Taxation have introduced policies such as first levy and then return, tax exemption, etc., but all of them have been repealed for many reasons. In order to obtain invoices for VAT input deduction and enjoying the policy of instant levy and instant refund, enterprises using waste materials mostly purchase waste materials through recycling enterprises and obtain VAT special invoices from recycling enterprises. This business model of "retailer-recycling enterprise-waste-using enterprise" has become the mainstream of current practice, in which the recycling enterprise reduces the tax burden of full tax payment due to the inability to obtain input invoice by enjoying the financial rebate in the park. However, this model has exposed a more general risk of false invoicing: "retailer - recycling enterprises - waste enterprises" transaction model exists in many links, many subjects, recycling link enterprises do not participate in the transportation of goods, warehousing and other phenomena, the case authorities may be no real goods transactions as a reason to deny the legitimacy of the entire chain of purchases and sales transactions on the chain of Involved in the purchase and sale transactions and open, subject to the invoice of the main body to file a case for investigation or co-investigation.

Under the current regulatory trend of strict investigation of tax rebates, recycling enterprises are facing more severe risks of applying financial rebate policies, and the financial rebates obtained based on invoicing and tax payment are facing the risks of being investigated and recovered, and whether there is any false invoicing in invoicing to downstream enterprises will become the gripping hand of this kind of cases. According to our agency experience and long-term observation, in the case of false invoicing of renewable resources, recycling enterprises and waste-using enterprises are involved to different degrees. Therefore, under the current circumstances, enterprises in the resources recycling industry are facing more serious risks of false invoicing.

Two High Judicial Interpretations Make Significant Changes to the Criminalization and Sentencing of the Crime of Fraudulently Opening VAT Special Purpose Invoices

The judicial interpretation responded to some controversies and voices in practice, such as in the aspect of incrimination, it is clear that inflated performance, financing, loans, etc. are not for the purpose of fraudulent offsetting of taxes, and if there is no fraudulent loss of taxes due to offsetting, the crime of fraudulent issuance of special invoices for value-added tax will not be punished; in the aspect of the standard of the amount of the sentencing, it will be more than ten years' fixed-term imprisonment or the amount of the standard of the amount of life imprisonment from the amount of taxes of more than two and a half million to more than five million, which responded to the issue of disproportionately heavy sentences, which had been highly called out. Previously called for a high degree of sentencing aberrant problem. It is worth noting that the judicial interpretation clarifies the sentencing criteria for the crime of fraudulent issuance of VAT invoices, if the subject involved in the case does not reach the amount of more than three years or more than ten years or more than ten years of imprisonment, but there are serious or particularly serious circumstances, they will also face the corresponding prison term. The clarification of the circumstantial standard may lead to the subject facing a higher sentence. In addition, the new Judicial Interpretation also emphasizes the punishment of complicity in fraudulent opening. Anyone who provides a bank account for the return of funds, knowing that the subject of the case has made a fraudulent opening, will be punished as an accomplice in the fraudulent opening of a bank account.

The following section will further analyze the key changes brought by the provisions of the new judicial interpretation on the crime of false VAT invoices to the handling of false invoicing cases in the resources recycling industry.

New Judicial Interpretation Reignites the Dispute between Purposeful and Behavioral Offenders of the Crime of Fraudulently Issuing Special VAT Invoices, and the Criminal Risks of the Resources Recycling Industry Become More Serious

The new Judicial Interpretation summarizes five cases of false invoicing of VAT, but still does not specify in the provisions that the purpose of cheating national tax and causing loss of national tax are the constituent elements of the crime. In practice, some case-handling authorities interpret the crime of false invoicing of VAT as a "behavioral crime", believing that as long as the perpetrator proceeds to commit the crime and reaches the degree required by the law, the criminal act is completed, and whether the perpetrator has the purpose of cheating and offsetting the tax or not, as well as whether the perpetrator has actually cheated and offset the tax or not, does not affect the determination of the crime.

The crime of false invoicing of VAT shall be a purposeful or behavioral crime which is quite controversial in practice. In fact, the Supreme People's Court has made it clear many times in its replies to opinions, symposiums and typical cases published that "the false invoicing behavior that does not subjectively have the purpose of stealing and cheating taxes, and objectively does not actually cause the loss of national taxes, does not constitute the crime of falsely issuing value-added special invoices". In the author's opinion, the crime of false invoicing of VAT belongs to non-statutory purpose crime, and if the constitutive elements of the crime of false invoicing of VAT are not restricted with the purpose of cheating national tax, the scope of punishment of this crime will be unduly expanded. The circumstances stipulated in the first paragraph of Article 10 of the Judicial Interpretation reflect the erosion of national taxes, and the second paragraph makes it clear that the crime of false VAT invoices is not punishable if the purpose is not to fraudulently offset the taxes, and if there is no fraudulent loss of taxes due to offsetting. Therefore, even if the legal provisions have not been clarified, in practice, the determination of false invoicing should be judged whether the perpetrator "subjectively has the purpose of cheating tax" and "objectively causes loss of tax".

Talking about the business model of renewable resources "retailers - recycling enterprises - waste enterprises", waste enterprises through the recycling enterprise collection of waste materials, purchase of waste materials, obtaining VAT invoices, waste enterprises with the actual purchase of goods at tax-inclusive price, and no false opening to cheat the state tax purposes, did not cause tax losses, such multi-link transaction This kind of multi-step transaction, one-stop transportation and one-ticket settlement is in line with the industry practice and reasonable, and should not be dealt with as the crime of false VAT invoices.

In practice, the recycling enterprise may be deceived by the downstream enterprise and invoices are issued more than once according to the business information provided by the enterprise. In this case, the recycling enterprise does not have the intention of fraudulent tax evasion and should not apply the new judicial interpretation of Article 10, paragraph 1, item 2, which stipulates that "there is actual business to be deducted, but the VAT invoices issued exceeding the tax corresponding to the actual business to be deducted, and other invoices used for fraudulently obtaining export tax rebate and tax deduction", and can strive for the application of the crime of not having the intention of fraudulent tax evasion. However, the Judicial Interpretation has been issued, and it is possible to fight for the application of the crime of no intent to cheat tax, so as not to be punished for the crime of falsely issuing VAT invoices.

However, after the issuance of the judicial interpretation, there may be some case-handling authorities who directly understand according to the provisions that only the subject involved in the case has committed the listed acts of false VAT invoices, that is, it constitutes the crime of false VAT invoicing. Recycling enterprises should pay attention to this criminal risk, seek professional support in time when involved in relevant charges, defend themselves in terms of the application of law and facts, and fully argue whether they have the subjective purpose of fraudulently offsetting the state tax and whether they have caused tax losses.

Raise the sentencing amount standard, activate the circumstance standard, and the criminal responsibility of recycling enterprises should not be underestimated

A fine of not less than 50,000 yuan and not more than 500,000 yuan; where the amount of tax falsely invoiced is huge or there are other particularly serious circumstances, the penalty shall be fixed-term imprisonment of not less than ten years or life imprisonment, and a fine of not less than 50,000 yuan and not more than 500,000 yuan or confiscation of property".

That is to say, the sentence for the crime of falsely issuing VAT invoices adopts the double standard of amount or circumstance, such as taking the imprisonment term of more than three years and less than ten years as an example, where the subject involved in the case reaches the larger amount of false invoicing or constitutes other serious circumstance, as long as it conforms to one of the foregoing circumstances, it will be sentenced to the same level of sentence. As for the specific amount standard and the circumstance standard, there are the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of the Decision of the Standing Committee of the National People's Congress on Punishing the Crimes of False, Counterfeit and Illegal Sale of VAT Special Invoice (Fafa [1996] No. 30), Interpretation of the Supreme People's Court on Several Issues on the Specific Application of Laws for the Trial of Criminal Cases of Fraudulent Export Tax Refunds ( Legal Interpretation [2002] No. 30) and Notice on Issues Relating to the Conviction and Sentencing Criteria for Fraudulently Issuing VAT Special Purpose Invoices (Fa [2018] No. 226) make specific provisions, and this time, the two High Court Judicial Interpretations revised both the amount and the circumstance criteria for sentencing for the crime of fraudulently issuing VAT Special Purpose Invoices.

I. Clarifying the criteria for filing a case for prosecution

Previously, the Provisions of the Supreme People's Procuratorate and the Ministry of Public Security on the Standards for Filing Criminal Cases under the Jurisdiction of the Public Security Organs (II) (Gongtong Zi [2022] No. 12) clarified that the amount of the crime of fraudulent VAT invoices filed for prosecution is more than 100,000 yuan or the loss of tax caused by more than 50,000 yuan, and this judicial interpretation confirms the amount of the standard of more than 100,000 yuan, that is, the amount of tax in the amount of more than 100,000 yuan of fraudulent VAT invoices may face a criminal charge. This judicial interpretation confirms and clarifies the standard of over 100,000 yuan, i.e., if the amount of tax in the special invoice is over 100,000 yuan, the person may face the charge of criminal offense.

II. Increase in the amount of the criterion for a term of imprisonment of more than 10 years to 5 million dollars

The Judicial Interpretation has raised the sentencing amount standard for the crime of fraudulent issuance of special VAT invoices for more than 10 years from the original two and a half million dollars to five million dollars. With the development of economy and society, the total volume of transactions has been rising year by year, and the original abnormally heavy sentencing amount standard is no longer in line with the reality. This amendment responds to the call to raise the sentencing amount standard, for the main body involved in the case is more favorable.

III. The two high judicial interpretations to activate the circumstances of the sentencing standards, the application of which may be increased

(I) There is a legislative gap in the circumstance standard for the crime of false VAT invoices.

As mentioned above, the sentencing for the crime of false invoicing of VAT is in accordance with the amount or circumstance standard, and if the subject involved in the case has "other serious circumstance" or "other particularly serious circumstance", it should be applied for more than three years and less than ten years and more than ten years, respectively. Previously, the circumstance standard stipulated in Law [1996] No. 30 was simpler and was mainly defined by the amount of tax fraudulently obtained by the state. After the issuance of Law [2018] No. 226, the sentencing standards of Fa Fa [1996] No. 30 were no longer applicable, and the amount standard was clarified again, but the definition of the circumstance standard was not stipulated any more, and there was a gap in the circumstance standard for the crime of fraudulently issuing VAT special invoices. The Supreme People's Court mentioned in the Understanding and Application of the Circular on Relevant Issues Concerning the Conviction and Sentencing Criteria for the Conviction and Sentencing of Unwarranted VAT Invoices that "on the basis of clarifying the amount standard that can be enforced by reference, the judicial practice should be able to basically satisfy the needs of the judicial practice by leaving the circumstances standard undefined and left to the discretion of the judicial practice. Moreover, the provisions of the Criminal Law on the crime of fraudulent issuance of special invoices for value-added tax are different from the crime of fraudulently obtaining export tax refunds, and there is a certain difference between the two crimes, so whether the conviction and sentencing standards can be completely equivalent requires further research and demonstration, and it is appropriate to refer to the specialized judicial interpretations to make it clear".

As the legislation has not made uniform provisions on the circumstance standard, there is a lack of operability in the application of sentencing, and in the judicial practice in recent years, the crime of fraudulent VAT invoicing has been convicted and sentenced according to the amount standard.

(II) The latest judicial interpretations of the two high courts have clarified the circumstance standard again, and the subjects involved in the case are facing the risk of escalation of the sentence.

The latest judicial interpretations of the two high courts have clarified the circumstantial standard of sentencing for the crime of issuing VAT invoices in vain, which has filled the blank of legislation and provided a guideline for the application of judicial practice, and the application of the circumstantial standard by the judicial authorities in the handling of cases in the future may increase, and the subjects involved in the case will face the risk of upgrading of the sentence.

Taking the sentence level of more than ten years of imprisonment or life imprisonment as an example, according to the provisions of the judicial interpretation of the two high courts, from the amount standard, the subject involved in the case of fraudulent tax amount of more than five million yuan, the "amount is huge", and shall be sentenced to more than ten years of imprisonment or life imprisonment. From the viewpoint of the circumstance standard, even if the amount of tax falsely invoiced by the subject involved in the case is below five million yuan, if it constitutes "other particularly serious circumstances", it is very likely to be sentenced to more than ten years of imprisonment or life imprisonment - (1) the amount of tax involved in the case shall be the same as the amount of tax falsely invoiced by the subject involved in the case.

(1) For enterprises with a tax amount between 3 million and 5 million RMB, if the amount of tax that cannot be recovered before prosecution is filed reaches 3 million RMB or more, the subject of the case will be sentenced to more than 10 years of imprisonment or life imprisonment. Simple example to illustrate this sentence, such as the enterprise false tax amount of 4.5 million yuan, from the amount of the standard does not reach the "huge amount" sentenced to more than ten years of imprisonment or life imprisonment, but if the enterprise in the prosecution before, only 1 million yuan of tax, can not be recovered amount of 3.5 million yuan of taxes, the Other particularly aggravating circumstances", the subject of the case will face more than ten years of imprisonment or life imprisonment.

(2) In addition to the amount of irrecoverable tax amounting to 3 million yuan before the filing of the indictment, if a person has been criminally punished or subjected to more than two administrative penalties for false invoicing within five years and the amount of false VAT invoices is more than 3 million yuan, he/she also belongs to the category of "other particularly aggravating circumstances", and will face a penalty of more than ten years' imprisonment or life imprisonment, which emphasizes the punishment of recidivism and repeated offenders and the punishment of repeated offenders. This article emphasizes the crackdown on recidivism and repeated offenders. Here we need to draw the attention of renewable resources enterprises to pay attention to the compliance management of invoicing and deduction in daily production and operation, and if they face administrative penalties due to false invoicing, they should respond positively by filing a reconsideration or a lawsuit and strive to resolve the disputes appropriately, so as to avoid becoming a "previous conviction" in a criminal case, which would result in an upgrading of the penalty period.

(III) Defining the time of irrecoverable tax as the time limit for the subject of the case to pay back the tax before filing a public indictment.

Previously, Fa Fa [1996] No. 30 expressed the loss of tax as "causing the national tax to be fraudulently obtained", and the judicial interpretation was amended to "irrecoverable tax". In practice, "causing national taxes to be fraudulently obtained" is easily recognized as the amount of fraudulent issuance, which leads to abnormally heavy penalties; whereas "irrecoverable tax loss" reflects the confirmation of the subject's ability to make up for the tax before prosecution, and is the best way for the subject to avoid paying the tax before the prosecution is brought. For the subject involved in the case who has the willingness and ability to pay back, it is the space for him to avoid the application of "other serious circumstances" or "other particularly serious circumstances" for sentencing. As to what is "irrecoverable tax loss", the judicial interpretation does not make it clear. In the author's view, for the recipient, only when the recipient unit has ceased to exist, or although it exists, but because of the capital is not low debt and can not be recovered losses and other circumstances can be included in the tax losses caused to the state. For the subject involved in the case who is still in continuous operation, it is not appropriate to include the unrecoverable tax loss in the scope of the case where the case-handling authority can recover the fraudulent tax from it; for the invoicing party, especially the recycling enterprises enjoying financial rebates in the resources recycling industry, the "unrecoverable tax" caused by this kind of invoicing party is related to the tax that the downstream invoiced enterprises actually offset, and the tax that the downstream invoiced enterprises actually offset is related to the tax that the invoiced entities have already ceased to exist, or although they exist, they cannot recover their losses due to their low capital and debts. The "unrecoverable tax" caused by such invoicing parties is related to the actual tax deducted by the downstream invoiced enterprises, and whether the "unrecoverable tax" is defined on the basis of the amount of tax ultimately deducted by the invoiced enterprises or on the basis of the amount of financial rebate obtained by the invoiced enterprises is yet to be clarified.

As for the definition of the node of irrecoverable tax loss, there has been a big controversy for a long time, and the Supreme People's Court pointed out at the symposium on the trial of economic crime cases held by some courts nationwide in 2004 that the node of irrecoverable tax loss should be determined before the pronouncement of the judgment of the first instance. The Judicial Interpretation clearly defines irrecoverable tax losses as the node "before the filing of a public indictment", and makes more stringent requirements for the statute of limitations for the subject involved in the case to make up for the tax payment.

If the same purchase or sale involves both a false entry and a false exit, the greater amount shall be punished

I. The determination of the amount of the "false input and false output" type of false invoicing crime has been controversial for a long time.

The fourth paragraph of Article 11 of the judicial interpretations of the two high courts stipulates that "in the name of the same purchase and sale business, both fraudulently open the input VAT invoices, used to fraudulently obtain export tax refunds, other invoices for tax deduction, and fraudulently open the item of the larger amount of the calculation".

In practice, there are mainly four different views on the sentencing amount standard for this type of cases with both false output and false input, one is that the amount of output tax should be recognized as the criminal amount; the second is that the amount of input tax should be recognized as the criminal amount; the third is that the amount of output tax and the amount of input tax together should be recognized as the criminal amount; and the fourth is that the amount of output tax and the amount of input tax in the amount of the larger amount of criminal amount, and the fourth is that the judicial interpretation clarifies the amount standard for this time. The fourth view is the amount standard clarified by the judicial interpretation.

In the resources recycling industry, recycling enterprises to solve the problem of source procurement can not obtain invoices, and then choose to increase the trade link, the increase of the recycling body through the enjoyment of financial rebates to reduce the tax burden, the formation of a retailer - recycling enterprise 1 - recycling enterprise 2 - waste enterprise business model (as shown in the figure above), this business model is more prevalent in the business of renewable resources recycling. However, in practice, due to the recycling enterprise 2 is not involved in the transportation of goods, and even not directly linked to the source of supply retailers, in the case of false invoicing most of the cases were found to have no actual business, then the invoice is easy to obtain and issued by the false invoicing, that is, "false in and false out". In fact, in the case of real goods transaction and truthful invoicing, such business mode of multi-link transaction, one-stop transportation and one-ticket settlement is in line with the industry practice and reasonable, and should not be dealt with as the crime of false invoicing of VAT special-purpose invoices.

II. How to determine the tax loss in the crime of "false inward and outward" type of false invoicing?

VAT as a kind of turnover tax, its taxation chain ring ring offset, to the general sale of goods, for example, the VAT rate of 13%, no matter how many flow through the link, the amount of VAT levied on the goods by the state can only be 13% of the final price of the goods. As a simple example, Company A sells goods and issues VAT special invoice to the buyer, and Company A pays the tax corresponding to the sales price according to the tax rate of 13%; at the same time, Company A can declare deduction to the tax authority by virtue of the tax paid by the VAT special invoice issued by the upstream enterprise in the process of purchasing raw materials, and Company A needs to bear the tax corresponding to the value-added portion only. Regardless of the subsequent flow of links, the VAT of this purchase and sale business will not exceed 13% of the final price of the goods. Therefore, in the business of "false input and false output", the output and input of false invoicing should not be calculated cumulatively, otherwise the amount of false invoicing tax may exceed 13% of the price of the goods. The judicial interpretation of the two high courts clarifies that the criminal amount of the "inflow and outflow" type of fraudulent invoicing "shall be calculated by the larger amount of it", which is a better solution than the view that the criminal amount shall be determined by the total amount of output tax and input tax. This is a progress compared with the view that "the total amount of output tax and input tax is recognized as the amount of crime".

However, there is some controversy on how to apply the circumstance standard for the sentencing of the "false input and false output" type of false invoicing. For the situation that the amount of input tax falsely invoiced is greater than the amount of output tax, the amount standard should be determined by the amount of input tax according to this judicial interpretation, and the enterprise involved in the case can avoid being recognized as the existence of "other serious circumstances" by paying back the tax. The enterprises involved in the case can avoid being recognized as having "other serious circumstances" or "other particularly serious circumstances" by paying back the tax, which will lead to the upgrading of the sentence, and strive for the space for sentencing. As for the case that the sales item of false invoicing is larger than the input item, and the amount of false invoicing is determined by the sales item, how the judicial authorities apply the circumstance standard of "unrecoverable tax" is the problem discussed in the previous article, in this regard, the author believes that the amount of tax that the downstream recipient enterprise finally deducts should be taken as the consideration of "unrecoverable tax". In this regard, the author believes that the amount of tax ultimately deducted by the downstream invoiced enterprise should be taken into account as the factor of "irrecoverable tax".

Strengthening the crackdown on the accomplices of fraudulent invoicing, recycling enterprises should pay attention to the proliferation of the risk of criminal liability for fraudulent invoicing

Article 19 of the Judicial Interpretations of the two high courts stipulates that "Anyone who knows that another person has committed a crime of jeopardizing tax collection and management and still provides him with an account number, a credit certificate or other assistance shall be punished as an accomplice to the corresponding crime".

The Judicial Interpretation clarifies the definition and criminal responsibility of the accomplices who commit the crime of jeopardizing tax collection and management. In the case of false VAT invoices, it is a common phenomenon that many accounts are involved in the return flow of funds in such cases, and the subjects involved in the case usually use the bank cards of their relatives and employees to carry out the flow of funds. In the case where the perpetrator knows that the subject involved in the case has committed false VAT invoicing, he still provides bank cards for the return of funds, and will face the charge of the crime of false VAT invoicing.

It should be noted that knowing means knowing or ought to know, and the burden of proof lies with the authorities handling the case, but for the presumption of "ought to know", which is subjective over objective, the standard of proof of "knowing" must be met and all reasonable doubts must be eliminated in the case of incrimination. In the resources recycling industry, those involved in the purchase and sale of waste materials should pay attention to the possibility of expanding the risk of such criminal liability and raise their awareness of compliance.

The two high judicial interpretations are lenient and strict, and respond to some controversial issues in practice. Under the current background of the eight departments' joint crackdown on the crime of false invoicing and strict investigation of tax rebates, renewable resources enterprises are facing a higher risk of criminal liability for false invoicing. Renewable resources enterprises should fully understand the revision of the judicial interpretation of the crime of fraudulent invoicing, adjust their business model, seek professional support when it comes to the risk of criminal liability, and fully communicate with the judicial authorities on the crime and non-crime of the case, the crime and the crime, and the circumstances of sentencing, so as to avoid any deviation of the judicial authorities from the overall characterization of the case, and to strive for a good characterization of the enterprise and the parties involved in the case. At the same time, we focus on the application and initiation of criminal compliance procedures, and strive to achieve good results through criminal compliance.