On July 18, 2023, the French Anticorruption Agency ("FAA") published its 2022 annual activity report. The report detailed key figures related to the inspections carried out by the agency, as well as the lessons to be learned....more
While there are a number of ways in which organizations may become aware of potential wrongdoing internally, perhaps the most significant for its legal and compliance teams is internal reporting, or “whistleblowing,” by...more
5/15/2023
/ Cross-Border ,
Cross-Border Transactions ,
Employment Rights Act ,
EU ,
Financial Conduct Authority (FCA) ,
Foreign Nationals ,
Securities and Exchange Commission (SEC) ,
UK ,
United Arab Emirates (UAE) ,
Whistleblower Protection Policies ,
Whistleblowers
In Short -
The Situation: The European Union's Fourth Anti-Money Laundering ("AML") Directive (Directive (EU) 2015/849 of May 20, 2015) granted broad access to information relating to the beneficial owners of companies...more
On March 14, 2023, the French Anticorruption Agency ("AFA") and the Parquet National Financier ("PNF") jointly published a new version of their guide relating to internal anticorruption investigations (the "Guide")....more
France's Orientation and Programming Law of the Ministry of the Interior ("LOMPI law"), published in the Official Journal of January 25, 2023, amends the insurance coverage of losses and damages paid in response to...more
2/27/2023
/ Cyber Attacks ,
Cyber Crimes ,
Cyber Insurance ,
Cybersecurity ,
Data Breach ,
Data Processors ,
France ,
Information Technology ,
Insurance Code ,
New Guidance ,
Popular ,
Ransomware ,
Regulatory Requirements
French Decree No. 2022-1284 of October 3, 2022, which implements French Law No. 2022-401 of March 21, 2022, on whistleblower protections (also known as the "Waserman Law"), came into effect on October 4, 2022 (the "New...more
The French Anti-Corruption Agency ("FAA") report details key statistics relating to the controls the FAA carried out in 2019 and lessons to be drawn from this activity.
On 9 July 2020, the FAA published its 2019 annual...more
7/20/2020
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Cooperation ,
Corruption ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Jurisdictions ,
France ,
Serious Fraud Office (SFO) ,
White Collar Crimes
The Financial Public Prosecutor and the French Anticorruption Agency ("FAA") have recently adopted guidelines on the implementation of the "convention judiciaire d'intérêt public" ("CJIP"), the French version of a deferred...more
8/16/2019
/ Anti-Corruption ,
Blocking Statutes ,
CJIP ,
Compliance ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Enforcement Authority ,
France ,
New Guidance ,
Public Prosecutors
The Enforcement Committee of the French Anticorruption Agency ("FAA") handed down its first decision on July 4, 2019. The decision follows the Agency's three-month audit (October to December 2017) of the involved company's...more
The Situation: Anticorruption legislation passed by French lawmakers in 2016 authorizes the resolution of a corruption matter by means of a "convention judiciaire d'intérêt public" ("CJIP"), the French version of a deferred...more
4/30/2018
/ Anti-Corruption ,
Bribery ,
CJIP ,
Criminal Investigations ,
Criminal Liability ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
European Court of Human Rights ,
France ,
French Supreme Court ,
Sapin II
The Situation: The French Anti-Corruption Agency has published the questions and documentation that companies will be expected to answer and provide when inspected by the Agency.
The Result: The French Anti-Corruption...more