Compliance in France in 2020

2019 and early 2020 proved very eventful for compliance and white-collar crime in France, especially for anti-bribery. Agencies are continuing to build on the 2016 'Sapin II' law by incrementally defining anti-corruption standards and stepping up their enforcement efforts on both the administrative and judicial fronts.

Discussion points

• French anti-bribery compliance law is now being built by improving on the 2016 Sapin II law with the AFA's various guidance documents and case law
• The first cases referred to the AFA's sanctions board in 2019 and 2020 confirm that bribery-related risks are now also administrative
• Recent judicial enforcement confirms the 'tough on white-collar crime' strategy and the success of CJIPs in enforcement actions
• France is considering updating its 1968 'blocking statute' to better supervise cross-border evidence collection
• The 2017 'Duty of vigilance' law is becoming a source of liability for large companies as NGOs organise to monitor compliance with the law
• Covid-19 disruptions are expected in courts and government agencies throughout 2020 and beyond

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Reproduced with permission from Law Business Research Ltd. This article was first published in June 2020

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