On a certain date, the WeChat official account of the National Security Ministry published an article titled "Hidden Surveying, Secret Leakage," stating that in recent years, with the National Security Organ intensifying its crackdown on illegal surveying activities, some foreign organizations have gradually shifted to collaborating with domestic enterprises on so-called projects to evade supervision, illegally collecting China's original surveying data, posing a threat to our national security.

I. New Trends in Illegal Surveying Activities by Foreign Institutions******（一）非法测绘猖獗，境外组织转向国内合作On a certain date, the national security authorities discovered that a foreign enterprise company, in collaboration with a Chinese company holding surveying and mapping qualifications, was illegally conducting geographic information surveying activities in China under the guise of conducting research on automotive intelligent driving. On one hand, the company, as a contractor for a key sensitive sector project in a certain country, does not have the qualifications to independently conduct geographic information surveying activities in China according to the "Surveying and Mapping Law of the People's Republic of China." To evade regulatory oversight by China's industry authorities, the company used the pretext of automotive intelligent driving research to repeatedly subcontract the project, ultimately entrusting it to a domestic company with surveying and mapping qualifications to implement. Under the lure of economic interests, the company completely became a puppet of the foreign company, and its surveying and mapping qualifications served as a cover for the foreign company to illegally obtain surveying data within China. On the other hand, the foreign company took a hands-on approach to guide and steal raw data. To directly obtain raw surveying data as much as possible, the foreign company bypassed the multiple layers of project subcontracting, taking full control of the surveying project's progress and directly directing the company's personnel to conduct surveying in multiple provinces across China. The foreign company even specially dispatched foreign technical experts to provide practical guidance to the company's surveying staff, focusing on controlling the storage, processing, and circulation of surveying data. Under the manipulation and instruction of the foreign company, the company transferred the obtained surveying data out of the country.（二）境外组织渗透，国内企业短视谋私逐财On one hand, foreign organizations engage in illegal surveying activities by "borrowing the shell" of domestic enterprises, which have multiple and covert purposes. Firstly, China has strict legal regulations on surveying activities, and foreign organizations themselves do not possess legal qualifications. By leveraging the legitimate facade of domestic enterprises, their illegal surveying activities become more covert, facilitating their operations within China. Secondly, through collaboration with domestic enterprises, they can directly command surveying work, precisely controlling key aspects such as data collection, storage, processing, and circulation, thereby obtaining high-quality original surveying data. Thirdly, the leaked data may be used for military strategic planning, providing geographic information support for their military actions, or for formulating targeted market strategies for their enterprises, gaining competitive advantages, or even interfering with and disrupting China's economic policies and industrial development. On the other hand, some domestic enterprises collaborate with foreign organizations to engage in illegal surveying activities due to short-sighted pursuit of profit. Tempted by economic benefits, some domestic enterprises fail to fully consider the legality of their actions and potential consequences. They hope to obtain project income and increase short-term enterprise revenue by undertaking foreign projects, ignoring the significant risks behind such collaborations. Additionally, once illegal surveying activities are exposed, enterprises will face legal sanctions and economic penalties, and their commercial reputation will be severely damaged, losing market trust and other legitimate business cooperation opportunities, causing irreparable losses to the long-term development of the enterprise. Therefore, most domestic enterprises involved in such "collaborations" often deny their involvement after the incident, attempting to salvage some reputation and social trust.（三）项目合作掩护，主管部门监管难度大增****Foreign organizations illegally collect and measure mapping data through so-called "project cooperation," significantly increasing regulatory difficulties. Such cooperation typically involves multiple stages. On the surface, they are legitimate commercial cooperation projects, and many foreign enterprises even collaborate with well-known domestic companies and institutions. This multi-layered, multi-stage cooperation method makes illegal surveying activities difficult to detect. Once exposed, foreign organizations and domestic participating companies often use compliance shells to evade legal responsibilities. For example, in company-to-company cooperation, a company uses smart driving research as a cover, subcontracts the project multiple times, and eventually forms a partnership with a company that has surveying qualifications. Under the temptation of economic interests, the company fully acts as a tool for the illegal acquisition of surveying data. On the surface, the company has surveying qualifications, appearing to be legal and compliant, but in essence, its qualifications become a tool to cover up illegal surveying activities. This type of behavior, using legal qualifications for illegal activities, on one hand, makes it difficult for regulators to effectively identify issues, easily leading to a crisis of social trust. On the other hand, the public finds it hard to distinguish whether a company is compliant or whether the enterprise is involved in illegal activities. Additionally, due to the complexity of transnational project cooperation, foreign forces often use层层转包、虚假合同等方式混淆视听, further increasing the difficulty for the state to regulate surveying activities.（四）企业发文澄清，回应公众疑虑表明立场**随着《隐秘的测绘，秘密的泄露》一文对非法测绘行为的披露，部分知名企业纷纷发文澄清。一方面，多方车企通过社交媒体发文回应。16日晚，吉利控股集团高级副总裁杨学良在微博回应，称此事“跟极氪无关，也不是极氪合作伙伴所为”。特斯拉对外事务副总裁陶琳也在微博上发文，表示合规是企业经营的底线，并强调特斯拉一直以来都严格遵守国家相关法规，不存在参与非法测绘的情况。同时，17日凌晨，Mobileye中国官方微博发布声明表示，其始终致力于推动道路安全技术的进步。“我们在数据安全与法律合规领域持续投入，在包括中国的相关国家和地区，我们在具备相关资质的合作方监督下全面依法经营。我们严格遵守所有相关法律法规，从而确保我们的运营符合最高的安全和合规标准。”另一方面，测绘公司四维图新同样发文声明。16日晚，四维图新表明，其作为一家合法合规的测绘企业，始终遵循国家的法律和规定，不会参与任何形式的非法测绘行为，并表示将采取法律手段维护公司的合法权益，追究那些发布虚假信息者的责任，坚决反对任何抹黑和中伤公司名誉的网络谣言。

II. Associated Risks Arising from Illegal Surveying Activities by Overseas Institutions******（一）法律监管风险一方面，监管难度增大。以合作为幌子加剧非法测绘行为隐蔽性，增加监管难度。例如，此案例中，A公司将项目多次外包，最终利用具有测绘资质的国内B公司实施，此复杂的合作层级与外包关系，使监管部门难以从众多正常的商业合作项目中快速甄别出非法测绘行为。监管部门需耗费大量人力、物力和时间梳理项目流与各方关系，增加监管成本与难度。另一方面，合作形式可能导致法律责任界定模糊。境内外企业勾结之下，对于非法测绘行为的责任划分在法律上可能存在争议。例如该案中，国内B公司可能以受境外A公司指使为由，试图逃避或减轻自身责任；而A公司可能利用不同国家的法律差异来规避责任追究，增加我国相关部门依法监管与惩处难度。 (2) Economic Interest Risks一方面，国内企业经济利益受损。国内企业在这种勾结中往往处于被动和不利地位。例如，此案例中，B公司在经济利益的诱惑下，虽然短期内可能获得一定的项目收入，但从长远看，由于其沦为境外A公司的“牵线木偶”，自身的市场竞争力和商业信誉受损。而非法测绘行为一旦被揭露，B公司除面临法律制裁和经济处罚外，还可能失去其他合法的商业合作机会，导致其长期经济利益受损。另一方面，可能扭曲市场竞争环境。境外企业或机构通过与国内企业或高校勾结，可能获得不正当的竞争优势。例如A公司借助B公司的测绘资质和资源、谷歌凭借强大技术和数据优势、境外科研机构利用高校的学术资源和学生劳动力，在非法获取我国测绘数据的同时，可能以更低的成本和更隐蔽的方式参与市场竞争，扰乱我国相关产业或学术领域的正常价格和竞争秩序，不利于我国测绘产业及科研环境的健康发展。（三）数据安全风险On one hand, the difficulty of data security management has increased. Using cooperation as a pretext has complicated data security management. For example, in cases involving companies, one company takes full control of the progress of surveying and mapping projects, directly commanding its personnel to conduct surveying and mapping, and appointing foreign technical experts to oversee key aspects, posing a serious threat to the security management of China's surveying and mapping data. Additionally, domestic enterprises or institutions may, due to a lack of vigilance towards foreign enterprises or institutions during cooperation, relax control over data security, making data more susceptible to theft or leakage. For instance, a company may ignore industry regulations in surveying and mapping, allowing foreign enterprises to control the flow of data, ultimately leading to the loss of control over original surveying and mapping data, which may contain information involving state secrets. Once leaked, this could pose a significant risk to China's national security. On the other hand, "cooperation" increases the risk of malicious use of data. After obtaining China's surveying and mapping data, foreign enterprises or institutions may use these data for various malicious purposes. For example, a company might use the data for military strategic planning or intelligence support in the economic field. In a case where a foreign research institution illegally conducted surveying and mapping in collaboration with a domestic university, the foreign research institution signed a cooperation agreement with the domestic university under the pretext of jointly researching environmental science and needing to collect relevant geographic data. During this cooperation, the foreign research institution might use the obtained data to hinder the formulation of China's environmental policies or ecological protection, thereby harming China's national interests.（四）社会信任风险**一方面，行业信任受损。以境内外勾结为手段的非法测绘行为会严重削弱我国测绘行业及相关领域的社会信任度。公众可能会对国内测绘工作产生怀疑。例如，当类似A公司与B公司被曝光后，公众可能会对国内测绘企业的专业性和诚信度产生怀疑，担心其他企业也存在类似的违法违规行为。从而影响国内测绘企业在市场上的信誉形象，降低公众对测绘行业及相关领域的信任度，进而可能影响整个行业或学术环境的发展。另一方面，社会信任受损还可能延伸到对相关监管部门的信任。境内外勾结进行非法测绘的行为大大增加有关部门监管难度，从而严重滞后对此行为的审查与监管工作。对此，公众如果认为监管部门无法有效防范和惩处这类非法测绘行为，可能会对监管部门的能力和公正性产生质疑，影响政府在公众心目中的形象与公信力，进而危害社会稳定和谐。

III. Recommendations for Dealing with Illegal Surveying Activities by Overseas Entities******（一）筑牢法律堤坝，明晰责任划分界限One is to establish a specialized regulatory mechanism for illegal surveying and mapping. Strengthen the review of complex cooperation forms. Establish a cross-departmental joint regulatory team to integrate resources, enhance the ability to identify covert illegal surveying and mapping activities, and reduce regulatory costs. Two is to clarify the standards for legal liability determination. Improve relevant laws and regulations, clearly define the responsibilities of all parties for different cooperation forms, and avoid situations where responsibilities are shirked and legal differences are exploited to evade responsibilities. Three is to strengthen international legal cooperation and coordination. Work with other countries to jointly formulate and improve international regulations on illegal surveying and mapping, enhance information sharing and law enforcement cooperation, and jointly combat illegal surveying and mapping activities through cross-border "cooperation."（二）坚守测绘底线，培育产业发展生机First, strengthen education and guidance for domestic enterprises and universities. Enhance their awareness of risks and legal issues, making them understand the severe consequences of illegal cooperation with foreign entities, and avoid being passively drawn in by economic temptations. Second, increase the punishment for illegal surveying and mapping activities to maintain market competition order. Severe penalties, including fines and revocation of qualifications, should be imposed on enterprises and institutions involved in illegal surveying and mapping, creating a fair competitive environment for legitimate businesses. Third, support the development of domestic surveying and mapping industries and scientific research. Increase financial investment and policy support for domestic surveying and mapping enterprises and university research, enhance their technical level and market competitiveness, and reduce reliance on foreign cooperation.（三）夯实数据堡垒，防范恶意利用风险One is to strengthen data security management. It requires domestic enterprises and universities to strictly comply with data security regulations in their cooperation, implementing strict controls over data collection, storage, and transmission to ensure data security. Two is to establish a data review mechanism. Overseas enterprises or institutions' data collection equipment and technologies are to be reviewed to prevent potential data security risks. At the same time, the scope and purpose of data in cooperative projects are to be strictly defined. Three is to enhance data security technology research and development. Increased funding and human resources are to be invested in developing advanced data encryption, protection, and monitoring technologies, thereby improving our country's data security protection capabilities.（四）重塑信任基石，彰显行业经营正气**一是加强信息公开和宣传。及时向公众公布非法测绘行为的查处情况，提高公众对监管部门工作的了解和信任度。同时，加强对测绘行业及相关领域的宣传，提高公众对其专业性和合法性的认识。二是建立行业信用体系。对测绘企业和高校进行信用评级，对违法违规行为进行记录和公示，提高行业自律水平，增强公众对测绘行业及相关领域的信任。三是鼓励公众参与监督。建立举报奖励机制，鼓励公众对非法测绘行为进行举报，提高社会监督力度，共同维护国家数据安全和社会信任。IV. Conclusion****非法测绘活动一直是威胁我国国家安全的重要因素之一，而目前境外组织“借壳”国内企业非法窃取测绘数据成为新手段。其致使法律监管困难、经济利益受损、数据安全受威胁、社会信任降低。对此，我国需筑牢防线，在法律上健全机制明确责任，产业中引导企业自律发展，数据管理强化安全保障，社会层面重塑信任。多方协同发力，形成全方位防御体系，有效遏制非法测绘，守护国家安全、经济稳定与社会和谐，推动测绘相关领域健康发展。

the writer

Li Heng, Associate Professor at the Bai Ze Strategy Research Institute, Southwest University of Political Science and Law; Wang Haoyu, Researcher at the Bai Ze Strategy Research Institute, Southwest University of Political Science and Law.

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Editor: Lv Mengting Responsible Editor: Chang Yuhao Reviewer: Ni Chunle