Answer ... The anti-corruption enforcement landscape has become more complex in the last few months:
- The Agence française anticorruption (AFA) considers that the implementation of anti-corruption programmes under the Sapin II Act should now have been completed.
- The AFA will be more demanding when conducting its inspections (since the grace period for implementation of the anti-corruption requirements is ending).
- The number of AFA personnel has increased, in particular persons in charge of on-site inspections.
- The types of companies under investigation have become broader (real estate construction companies, pharmaceutical enterprises, automobile manufacturers and now the banking industry have all been the object of AFA audits).
- The AFA is now more willing to impose heavier sanctions so as to pressure companies within its scope of audit to implement serious, robust and effective anti-corruption programmes.
The AFA continues to update its recommendations in order to assist relevant entities in understanding how the Sapin II Act requirements should be interpreted and applied.