For the past two years, anticorruption compliance has been the hot topic in international legal circles in Asia. Spurred in particular by a perception of stepped-up enforcement of the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, lawyers have endlessly touted the need for their clients operating in the region to make sure everyone plays by the rules.

So the sweeping allegations made by the Chinese government against British pharmaceutical giant GlaxoSmithKline (GSK) have taken some by surprise. China’s Ministry of Public Security says it is investigating whether the company paid almost $500 million in bribes, mainly to doctors who prescribed its products.

“There are a number of my clients with very sophisticated compliance programs, and given GSK's size in China and their statements so far, I would expect they have a robust compliance program as well,” says Hogan Lovells Shanghai partner Eugene Chen. “As a result, I am surprised by seeing the magnitude of the conduct being alleged. At least by public statements, it seems GSK was surprised by it too.”