On July 4, the French Anticorruption Agency’s (AFA) Sanctions Committee rendered its first decision, dismissing all claims raised by the AFA and ruling that at the date of the hearing, the defendant company had implemented a system of detection and prevention of corruption which complied with the obligations imposed by Article 17 of Sapin II.… Continue Reading
On July 4, the French Anti-Corruption Agency (AFA) issued its first decision on whether a company should be sanctioned for an insufficient corruption prevention program, pursuant to the landmark 2016 Law Sapin II (article 17).… Continue Reading
The Sanctions Committee of the French Anti-Corruption Agency (AFA) held its first-ever hearing, meeting on June 25 to consider a company that is facing possible sanctions for failing to implement an effective anti-corruption compliance program.… Continue Reading
Former French Finance Minister Michel Sapin and four other panelists convened last week at the Panthéon-Assas University’s historical Place du Panthéon campus in Paris to discuss the application of the Sapin II law that came into effect in December 2016.… Continue Reading
On May 24, I wrote a post for the FCPA Blog about TRACE’s concerns that Article 10 of the new EU General Data Protection Regulation (GDPR) presents an obstacle to anti-bribery due diligence of third parties, and how we have advocated for an EU-wide, or at least a national-level, solution.… Continue Reading
The Special Investigative Commission of the National Assembly has released a report on the conditions surrounding foreign investments in French companies of strategic importance.
While the report discusses French industrial policy in the context of globalization more broadly, it also provides insight into how the French government may strengthen the Agence Française Anticorruption (AFA) and its ability to cooperate with foreign regulators on investigations involving corruption.… Continue Reading
There is some recent news from the front lines concerning the Agence Française Anti-Corruption’s and French prosecutor’s actions against companies that violate the French Anti-Corruption Law, Sapin II, and the use of the Convention Judiciaire d’Interêt Public.… Continue Reading
After two hours of driving through undeveloped Korean countryside, the image upon arriving at the Olympic skiing venues is quite startling: the surrounding ridges are dotted with technologically advanced, energy-generating windmills.… Continue Reading
The Geneva-based private banking unit of HSBC entered into France’s first deferred prosecution agreement Tuesday under the country’s new anti-corruption regime.
HSBC helped French clients evade local taxes and launder money, the DPA said.… Continue Reading
In December 2016, France enacted an anti-corruption law known as Sapin II. The law was named after Michel Sapin, the then Minister of Finance, who said when presenting the bill: “In the fight against corruption, France cannot just satisfy itself with the existing situation.”… Continue Reading
Some would argue that not-for-profits have done their job after campaigning for the UK Bribery Act and France’s Loi Sapin II, and indeed for the OECD Anti-Bribery Convention, and should now leave compliance to others. … Continue Reading
After a lengthy legislative process between the National Assembly and the Senate, Sapin II, the French anti-corruption law focused on transparency and modernization of economic activity, was passed, in its final form, by the National Assembly on November 8, with a majority vote of 308 to 171.… Continue Reading