It has been two years since Sapin II came into effect, with the broad goal of ensuring that French companies have robust anti-corruption and compliance regimes. What has been the application of it so far and what changes has it actually brought on ground level? The inaugural GIR Live Paris conference will not only focus on developments in the national investigations sphere but also on the extraterritorial reach of the new legislation, and how best to navigate it.
There will be three sessions:
- Internal investigations in France: the view from ground-level
- The rise and role of anti-corruption agencies in France: internal investigations and compliance
- French DPAs and international cooperation
FRA Partner, Yousr Khalil, will be joining the panel for session three. An outline of what will be discussed is below.
Sapin II has created a French version of the DPA (CJIP), which allows the public prosecutor to conclude a plea agreement with entities accused of corruption, influence peddling, tax fraud, the proceeds of tax fraud, or related offenses. This panel will examine cases of this tool being used, focusing on the interplay between French and foreign authorities. Questions they are expected to discuss include:
- Are there disputes between the district prosecutor’s offices and the PNF over which agency takes investigations?
- Do French companies see the value in self-reporting to French authorities? Is it any different post-UBS?
- When to cooperate? Is it better to talk to authorities early, or wait until the case is accepted by an investigative judge?
- Are we any clearer on what a company must do to be offered a CJIP?
- Is settlement with multiple authorities only making fines bigger?
- Do French companies still fear the DOJ more than French authorities?
- Do we know what French monitorship looks like?
Astrid Mignon Colombet, Soulez Larivière & Associés
Yousr Khalil, FRA
Stephane de Navacelle, Navacelle