Comparative Guides

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4. Results: Answers
Anti-Corruption & Bribery
Tips and traps
What are your top tips for the smooth implementation of a robust anti-corruption compliance programme and what potential sticking points would you highlight?

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.

For more information about this answer please contact: Jean-Baptiste Poulle from Spitz Poulle Kannan