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Documentary letter of credit fraud under criminal law regime in England and China

Yanan Zhang (Department of Law, University of Eastern Finland, Joensuu, Finland)

Journal of Financial Crime

ISSN: 1359-0790

Article publication date: 30 September 2014



The purpose of this paper mainly is to examine the relevant rules concerning documentary letter of credit (L/C) fraud under criminal law in England and China.


The paper analyses the regulations about such crime and relevant literature.


The similarities and differences of such rules have been identified briefly. L/C fraud is considered a conduct crime; and unspecific or vague provisions concerning this crime may cause difficulties of application in judicial practice in both England and China. But the possible punishment for L/C fraud criminals under Chinese criminal law seems more severe than that under English law. Dealing with L/C fraud in international trade under national criminal laws is not effective. Regional and international efforts on legal assistance in cross-border criminal cases still remain to be improved.

Research limitations/implications

The limitation is that it examines merely relevant substantial rules in legislation. This opens the paths to future research on the approach towards L/C fraud demonstrated in court cases in England and in China.

Social implications

The research underlies the need to take serious attitude and make more effective efforts towards cross-border criminal cases, although different countries may have different rules concerning specific economic crimes.


This paper fills the gap of a comparative study on how L/C is regulated under criminal law regime in England and China.



This article derives partly from the author's PhD dissertation “Approaches to Resolving the International Documentary Letters of Credit Fraud Issue”, which was published by University of Eastern Finland in January 2011 (Publications of the University of Eastern Finland, Dissertations in Social Sciences and Business Studies No 15). The author is very thankful to Professor Matti Tolvanen (University of Eastern Finland) and Professor Soili Nystén-Haarala (University of Lapland) for their comments.


Zhang, Y. (2014), "Documentary letter of credit fraud under criminal law regime in England and China", Journal of Financial Crime, Vol. 21 No. 4, pp. 433-446.



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