Hong Kong's anti-corruption model won't work on mainland China
Sonny Lo says the advocates of a Hong-Kong-style fight against corruption on the mainland misunderstand the nature of the scourge across the border, and the tools available to fight it

Mainland China's anti-corruption campaign has been gathering pace since Xi Jinping became president in March. Members of the Politburo's Standing Committee reportedly voted against a proposal this summer to adopt a Hong-Kong-style amnesty of corrupt officials.
Despite the fact that some China watchers believe the mainland has much to learn from the Hong Kong model of fighting corruption, the reality is that Beijing's approach will remain a far cry from that of Hong Kong.
First and foremost, the amnesty of corrupt Hong Kong police officers, introduced by then governor Murray MacLehose in 1977 soon after a police mutiny in that year, cannot be replicated across the border. Doing so would be tantamount to a slap in the face for the anti-corruption campaign and a contradiction of China's criminal law, according to hardliners in the Politburo.
The ‘protective umbrella’ on the mainland is vast, with complex personal networks
Second, Hong Kong's anti-corruption fight is led by the powerful Independent Commission Against Corruption, but the mainland situation is complicated by the unique institutional design of the Central Commission for Discipline Inspection. At the provincial and city levels, the anti-corruption fight is constrained by the need to be accountable to the top levels, and most importantly to be answerable to the local party secretary. If the party secretary is somehow involved in corruption, he or she becomes a "protective umbrella" obstructing anti-corruption efforts. The ICAC does not have this problem.
Third, the "protective umbrella" on the mainland is vast, with complex personal networks involving party cadres, officials, businesspeople, land developers and professionals. The recent anti-corruption campaign targeting club memberships, for example, is testimony to the extensive networks of bribery. Unless a Maoist-style education campaign is launched, to teach all citizens the importance of clean government and ethics, it will be difficult to instil these values into the minds of all party cadres and government officials, not to mention ordinary citizens.
In Hong Kong, the ICAC can employ legal measures against any "protective umbrella", which won't be tolerated by the elite or the people.
Fourth, defying conventional wisdom that assumes severe penalties would be imposed on those found guilty of corruption, the reality is that, on the mainland, suspended death sentences often provide an opportunity for offenders to have their sentences reduced later, especially if they show good behaviour in the early stages of imprisonment. At best, some "small tigers" have been executed, as an example. In Hong Kong, those committing corrupt acts face the very real risk of severe punishment; this isn't really the case on the mainland.