Il y a cinq ans, la France a promulgué sa loi anti-corruption, dite loi Sapin II1. Cette loi a introduit des innovations importantes, y compris la possibilité pour les entreprises de se voir proposer et de négocier une...more
Five years ago, France enacted its anti-corruption legislation, Sapin II. The law introduced a number of important innovations, including the ability for companies to be offered and to negotiate a French-style deferred...more
On 23 February 2022, the European Commission adopted a proposal for a Directive on corporate sustainability due diligence. The impact of this legislation on companies meeting the required thresholds based in the EU and doing...more
3/4/2022
/ Capital Investments ,
Cooperative Compliance Regime ,
Corporate Governance ,
Corporate Social Responsibility ,
Disclosure Requirements ,
Due Diligence ,
Environmental Social & Governance (ESG) ,
EU ,
Human Rights ,
Small and Medium-Sized Enterprises (SMEs) ,
Supply Chain ,
Sustainability
There is an increasing legislative trend towards holding companies accountable for their own ESG practices as well as those of business partners within their supply chain.
...more
Il y a presque cinq ans, la France a promulgué sa loi anti-corruption, dite loi Sapin II. Cette loi, considérée comme disruptive à l'époque, a introduit des innovations importantes, y compris la possibilité pour les...more
1/6/2022
/ Anti-Corruption ,
Bribery ,
CJIP ,
Compliance Management Systems ,
Corruption ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
EU ,
Foreign Corporations ,
Foreign Jurisdictions ,
France ,
Internal Controls ,
Pending Legislation ,
Regulatory Agenda ,
Sapin II ,
Whistleblower Protection Policies ,
White Collar Crimes
Almost five years ago, France enacted its anti-corruption legislation, Sapin II. The law was considered ground-breaking at the time and introduced a number of important innovations, including the ability for companies to be...more
1/6/2022
/ Anti-Corruption ,
Bribery ,
CJIP ,
Compliance Management Systems ,
Corporate Counsel ,
Corruption ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
EU ,
Foreign Corporations ,
Foreign Jurisdictions ,
France ,
Internal Controls ,
Pending Legislation ,
Regulatory Agenda ,
Sapin II ,
Whistleblower Protection Policies ,
White Collar Crimes
Since the enactment of Sapin II, the lead French investigating and prosecuting agencies have entered into eleven Conventions Judiciaire d’Intérêt Public (“CJIPs”), which are the French equivalent of deferred prosecution...more
France is off to a strong start enforcing Sapin II, its December 2016 anti-corruption legislation. Since the enactment of the statute, the lead French investigating and prosecuting agencies, the Parquet National Financier...more
8/8/2019
/ Anti-Corruption ,
CJIP ,
Confidentiality Policies ,
Cooperation Agreement ,
Corporate Monitoring ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fines ,
France ,
Litigation Privilege ,
New Guidance ,
Prior Conviction ,
Sapin II ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
UK ,
United States ,
Voluntary Disclosure
The High Court has delivered an important judgment on the application of legal advice privilege to factual reports delivered by lawyers to their clients in the context of a regulatory investigation.
In the case of Property...more
The Sentencing Council’s Definitive Guidance for Fraud, Bribery and Money Laundering Offences (the “UK Guidelines”) came into force on 1 October 2014. The UK Guidelines set out a ten step process for sentencing and apply to...more
The Financial Conduct Authority (FCA) and the Bank of England Prudential Regulation Authority (PRA) published a report on 30 July 2014 that recommends that no financial incentives are given to whistleblowers. This differs...more
The Crime and Courts Bill which received Royal Assent on 25 April 2013 has introduced a new enforcement tool in the UK for fraud, bribery and money laundering offences. The Crime and Courts Act 2013 (the “Act”) which is...more