The French Law n°2016-1691 of 9 December 2016 relating to transparency, the fight against corruption, and the modernization of economic life, known as the “Sapin II” Act 1)Sapin II entered into force on 10 December 2016 (JORF n°0287 of Dec. 10, 2016) introduced to legal entities additional compliance requirements to address corruption in order for France to meet the highest European and international standards.
Sapin II has established a general principle of prevention and detection of corruption risks under the control of a national anticorruption structure, the French Anti-Corruption Agency (AFA), whose main mission is to help economic and public players in the process.
The AFA noted in its 2019 annual activity report 2)French Anti-Corruption Agencyn Annual Activity Report 2019 (7 July 2020) (in French).that anticorruption measures implemented by economic and public players were still incomplete.
On 12 January 2021, the AFA published new recommendations entered into force on 13 January 2021 (Recommendations, here in French).
The AFA specifies the practical procedures for implementing an anticorruption system structured around three foundational principles, namely:
- Governing body’s commitment;
- Understanding the entity’s exposure to probity risks; and
- Risk management.
|↑1||Sapin II entered into force on 10 December 2016 (JORF n°0287 of Dec. 10, 2016)|
|↑2||French Anti-Corruption Agencyn Annual Activity Report 2019 (7 July 2020) (in French).|