Can a foreign NGO without a representative office give money to individuals in China?
Based on the text of the Foreign NGO Law, it does not appear that foreign NGOs can lawfully give grants directly to individuals, such as for travel to workshops outside China, without a Chinese Partner as an intermediary. Article 22 states that individuals may not receive or spend any project funds that were not delivered through a Chinese Partner’s bank account. According to the NGOs in China Blog’s summary of guidance provided by the Ministry of Public Security at a 2016 Q&A session, individuals cannot be official Chinese Partners.