Evaluating the French Regulators’ Draft Anti-Corruption Internal Investigation Guidance

It has been five years since France adopted its groundbreaking anti-corruption law, known as Sapin II, and the anti-corruption and compliance environment within France continues to evolve rapidly, with the Agence Française Anticorruption and Parquet National Financier introducing a new draft Practical Guide Relating to Anti-Corruption Internal Investigations. In this guest article, Bryan Sillaman and Marie-Agnès Nicolas, partners at Hughes Hubbard, assess the guide and its implications, suggest improvements to it, and discuss the paradigm shift that Sapin II introduced in terms of how companies approach corporate wrongdoing. See “How to Assess Risk Under Sapin II” (Dec. 11, 2019).

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