In recent years, China has undertaken a massive crackdown on corruption that has led to charges against a number of high-ranking officials. But should China be considered a kleptocracy? This paper argues that for a country to merit this label, several key features beyond just endemic corruption must be present. A kleptocracy is a regime organized for the purposes of plunder, in which the state leadership acts as a vertically integrated, organized-crime syndicate with a degree of monopolistic control over the state and economy. Recent analysis has highlighted other important characteristics of kleptocracies, including the export of ill-gotten gains to foreign safe havens and their deployment for political purposes abroad. Considered against these criteria, China diverges markedly from the kleptocratic model and instead illustrates a distinct, more diffuse form of widespread corruption.