Comparing Anti-Corruption Guidance In France, UK And US

By Philippe Bouchez El Ghozi and Morgan Heavener (April 6, 2018, 12:16 PM EDT) -- The new French anti-corruption agency (Agence Française Anticorruption, or AFA) recently issued a set of guidelines detailing the AFA's expectations for corporate compliance programs.[1] The guidelines, which are not legally binding but which are required by France's Sapin II law and followed a period of public consultation, provide public and private commercial organizations with a framework for ensuring that their compliance programs adequately protect the organizations from corruption-related risks. [2] The guidelines are also intended to help certain commercial organizations meet the statutory requirements of Article 17 of Sapin II, which requires French companies (including the French subsidiaries of foreign companies) with over 500 employees and annual revenues exceeding €100 million to adopt certain identified compliance program requirements.[3]...

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