International Regulatory Enforcement (PHIRE)

Tailor-Made Compliance for Galloping Corruption

April 10, 2018

Philippe Bouchez

Forty years after the adoption of the Foreign Corrupt Practices Act ("FCPA") in the United States, twenty years after the adoption of the OECD Anti-Bribery Convention, and six years after the adoption of the U.K. Bribery Act ("UKBA"), the French law dated December 9, 2016, known as Sapin 2, obliges many French companies (with turnover greater than 100 million euros and at least 500 employees) to have to seriously and concretely integrate a strong anti-corruption approach to a risk that is often underestimated or poorly apprehended.

• The design and improvement of a compliance program requires tailor-made adaptation to the needs and reality of the company.

• Risk mapping requires special attention as it must justify choices made under the compliance program.

• The insufficiency of a compliance program poses a strong risk of sanctions on legal persons.

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