The Translator's Card

For five years I carried a business card in my wallet marked "translator," with a phone number.

It wasn't for a translator.

The card was given to me by one of our lawyers when I arrived in Shanghai in 2009. As he explained it to me, the authorities in China could detain you for an extended period without informing anyone where you were being held, or on what grounds. You would not be permitted to call a lawyer. You would, however, be permitted to call your translator.

I never needed the card in the 5 years I lived and worked there. I never had a single issue with the authorities, and I was never aware of the organisation I led doing anything that would have warranted one. But I've thought about that card twice in the last fortnight. Once when I wrote The Costless Commitment, asking why WPP had chosen this particular moment to publish a set of trust principles. And once more when the answer to that question may have arrived from a courtroom in Shanghai.

On 24 June, Bloomberg reported that Di Fei, the former Chief Investment Officer of GroupM China (WPP's media-buying operation in its largest Asian market) had been sentenced to life in prison. Two former colleagues, Yao Lan and Hong Xin, received 14.5 years and four years respectively. The court found they had taken kickbacks totalling 1.2 billion yuan (about $176 million) between 2019 and 2023, in exchange for directing WPP's ad-placing business to broker firms.

The three were detained in October 2023, when economic-crime police raided GroupM's Shanghai office. The convictions came in March 2026. That is roughly twenty-nine months in detention before a verdict, consistent with my understanding, from people who know the market well, that the defendants have been held throughout. The judgment itself is sealed. Everything the world knows about one of the largest private-sector bribery cases in Chinese history comes from anonymous sources speaking to Bloomberg, because court documents and hearings in China are strictly controlled. Di has appealed. A decision is expected late this year or in early 2027.

But the courtroom argument was never about whether the money was taken. It was about whose money it was. And both answers on offer were wrong.

The prosecution's theory: bribery. Broker firms paid the three executives to receive WPP's business which is a crime, in Chinese law, committed against the employer whose interests were betrayed.

The defence's theory, now the spine of Di's appeal, is stranger and more revealing. His lawyers argue the funds were rebates handled on behalf of WPP, that it was money under WPP's de facto control, given the company's power over its subcontractors and that taking it was therefore misappropriation of company funds, not bribery. A theft from WPP, which carries a lighter sentence than a betrayal of WPP.

Follow the money one step further back than either theory does, and you find the omission.

According to the accounts of the hearings, the scheme worked like this. GroupM outsourced media buying to brokers. The brokers pooled budgets from different clients to hit volume thresholds and extract rebates from media owners, rebates that sometimes reached about 20% of a client's entire ad budget. The brokers kept a share of those rebates as business income rather than returning them. Slices flowed onward into accounts linked to the three defendants. And the court also heard that WPP itself took a share of that broker revenue, by requesting the subcontractors buy its products, extend extra discounts, or provide free services. The brokers, per these accounts, felt obliged to cooperate to keep the business.

So the prosecution says the money was WPP's trust, abused. The defence says the money was WPP's property, taken. The brokers treated it as their income. And the court heard WPP extracted its own share of the same stream.

Four parties, four claims on the money. Not one of those claims belongs to the advertisers whose budgets generated every yuan of it.

In corruption cases there is only ever one source of overflow. Here, that place was clients' media budgets. The clients are the missing plaintiff. They were not in the courtroom, they are not named in the theories, and under a sealed judgment they may never learn precisely how much of their money leaked, or where.

Before this reads as another verdict against one company, the record cuts the other way on several points and they're not small ones.

WPP was not a party to the proceedings. When the raid came in October 2023, the company fired the detained executive, suspended trading with the implicated brokers, brought in an independent third party to run its own investigation, and cooperated fully with the authorities. Its own statement last month says it "respects the court's decision." Within months it had rebuilt its China leadership entirely. That is not the behaviour of a company protecting a scheme; it's the behaviour of a company excising one.

Scepticism should also run toward the source material. Everything here rests on anonymous accounts of a sealed process in a justice system that publishes no timeline and permits no scrutiny. Its' the the very system that put a fake translator's card in my wallet. Di disputes both the characterisation and the amount, and his appeal is live. And the Chinese trade press has been blunt that rebate leakage is an industry norm, not a WPP invention: the standard commentary after the arrests described kickbacks as 行规 ("the rules of the trade") running anywhere from 5% to 30% depending on the media type. WPP simply ran the biggest operation, which made it the biggest target.

But here's the thing. A $176 million diversion, sustained over four years, through a broker network handling budgets for the world's biggest advertisers. The arithmetic of a scheme that size rarely stops at three names, and the sealed judgment means we will likely never know where else it flowed. What we do know is who funded it.

If Shanghai were an isolated aberration, the story would end there. It isn't, because the same question of "whose money is the rebate?" is currently being litigated in the Supreme Court of New York.

Richard Foster spent seventeen years at GroupM, ending as global CEO of Motion Content Group, the unit behind Love Island. He was let go in July 2025 and in November he sued WPP for more than $100 million, alleging he was fired for repeatedly warning that GroupM systematically retained rebates that should have flowed back to advertisers. His complaint estimates that over five years, rebate-driven deals generated $3–4 billion in value, of which GroupM improperly kept $1.5–2 billion, reclassifying discounted inventory as "proprietary media" and reselling it to clients at a margin. His internal memo warned the company was "sleepwalking to the edge of a cliff."

WPP's defence is vigorous. It says Foster is a disgruntled former employee whose entire division was eliminated in a documented restructuring, that his supposed whistleblower report was in fact a pitch for his own promotion, and that he offered silence in exchange for a bigger severance. The court has made no findings, and may never, most observers expect a settlement before discovery exposes more internal communications. Notably, in fighting the case, WPP filed a 35-page internal document into the public record this February that disclosed the detailed spending of clients including Google, Coca-Cola, Unilever and Ford with more than $9 billion of client media data, now public. In a case about whether client money was treated as the agency's own, the agency's defence exhibit was a spreadsheet of its clients' money.

Shanghai and New York are different legal systems, different facts, different standards of proof. But they are the same question asked twice: when value is generated by aggregating client budgets, and that value leaks somewhere between the client and the media owner, who did it belong to?

Which brings me back to the question I couldn't answer a week ago.

On 22 June, the opening day of Cannes Lions, Cindy Rose published WPP's five trust principles. The fifth commits to accountability for client growth, and its elaboration reads, verbatim: "Our clients' media budgets are theirs and it is our responsibility to maximise return on this investment for clients." At Campaign House the same day, per Campaign's reporting, Rose acknowledged that WPP has faced its own questions on trust (Campaign cited the China case and the Foster suit) saying: "we're not going to be perfect all the time. No company is, but now we have a framework to filter all of this stuff through."

On 24 June, Bloomberg published the sentencing. The convictions had been handed down in March, inside a sealed system. In The Costless Commitment I asked what the trust principles would actually cost WPP, and why they had appeared now, unprompted. I couldn't see the prompt.

Perhaps the timing was coincidental. But Cannes is where you launch things, not where you defend things. And a fifth principle declaring that clients' media budgets are theirs reads rather differently once you know that, two days later, the world would learn what a Shanghai court had spent two years hearing about those budgets.

So here's my question for you: when your media money moves through layers you can't see who is your translator's card? Your agency? Your auditor? Or a clause in a contract you haven't re-read since the pitch?

Brandflow is written by Justin Billingsley, who has spent his career on all three sides of the industry's table: senior client, global agency leader, technology founder. First published 9 July 2026 in the Brandflow newsletter on LinkedIn.