Compliance Perspectives: The French AFA on their Anti-Corruption Activities and Guidance ("Sapin 2 Law")
Everything Compliance-Episode 3
FCPA Compliance Report-Episode 293, Saskia Zandieh on the new French Anti-Corruption law, Sapin II
Cross-jurisdiction cooperation in the fight against international corruption and bribery is intensifying. The UK’s Serious Fraud Office (SFO), France’s National Financial Prosecutor’s Office (PNF), and Switzerland’s Office of...more
In 2016 France adopted a new law to help combat corruption. Inspired by legislation in the US, UK and Netherlands, Article 17 of what is known as Sapin II, includes provisions requiring organizations above a certain size to...more
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
Starting from the conviction that the collaborative work between French professionals of the Compliance realm brings a new approach of the risk management, the association “Le Cercle de la Compliance” or “The Circle of the...more
No matter the industry, maintaining effective corporate compliance programs has never been a more essential part of operations to address the legal risks that corporates face. This article, the third in a series about...more
As more countries enter into the anti-corruption enforcement world, companies face exponential risks of detection and enforcement. Recently, Deputy Attorney General Rosenstein has commented on the need to avoid unfair...more
On November 30, 2017, the Institut des Hautes Etudes sur la Justice (IHEJ) and Skadden hosted a roundtable at the Cercle de l’Union Interalliée in Paris to discuss new perspectives on the Sapin II Act and cross-border...more
In a move that could signal a new phase of government enforcement in France, on November 27, 2017, French authorities published a Convention judiciaire d’intérêt public (CJIP) with HSBC Private Bank Suisse SA (HSBC PB), the...more
The Group of States against Corruption of the Council of Europe (GRECO) released a report on 28 September 2017 of its assessment of the measures adopted by France to fight against corruption following the recommendations it...more
Wrong. The law Sapin II (Law 2016-1691 of 27 December 2016) has been in force for several months, but the consultation draft of the guidelines is not expected to be issued by the Agence Française Anti-corruption (AFA) (French...more
Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation. Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more
La loi n° 2016-1691 relative à la transparence, à la lutte contre la corruption et à la modernisation de la vie économique (dite « Sapin II ») est parue au Journal Officiel le 10 décembre 2016. Elle a vocation, selon le...more
A new French law titled “Transparency, the Fight Against Corruption and Modernization of the Economy,” which was published in the French Official Journal on December 10, 2016 (known as Sapin II, as it was named after the...more
A piece of major compliance legislation has just been passed in Europe: the long-awaited French anti-corruption and whistleblower protection law, Sapin II, which brings French anti-corruption standards in line with those of...more
After years of facing international criticism for purported “laxity” towards transparency and the fight against bribery and corruption, France has adopted new legislation aiming to rectify this deficiency, which imposes...more