Article
First “Direct” Pecuniary Sanction Under Sapin II: Compliance Lessons From Decision 25-01 (Société V And MS)
France's Anti-Corruption Agency has imposed its first direct financial penalties under the Sapin II Law on a holding company and its executive for failing to implement required corruption prevention measures, marking a significant shift in enforcement approach. The decision establishes that compliance deficiencies are assessed at the audit date rather than when remediation occurs, and that senior executives may face personal liability for non-compliance. What does this landmark ruling mean for multinational
Mayer Brown