The Securities Law of China has been updated to address issues, with the Supreme People’s Court making rulings on securities fraud litigation. However, there are still problems like the lack of private lawsuit remedy for investors and difficulties in pursuing class actions. In the US, securities fraud litigation is dynamic but flawed. China aims to avoid similar issues by limiting lawsuits against state-controlled issuers. Germany and Taiwan have experimented with different approaches. To improve, China should encourage more private participation in its markets.