Compliance – French Anti-Corruption Agency: The Sanctions Commission favours pedagogy

On 7 February 2020, the Sanctions Commission of the French Anti-Corruption Agency (AFA) issued its second decision since its creation, following its referral by the Director of the AFA for three alleged breaches of the Sapin II law.

The Commission considers the criticisms of the Director of AFA on the risk mapping of the company to be ineffective since the preparation of an action plan resulting from the risk mapping has no legal basis and is based exclusively on the recommendations of AFA.

Finally, if, for the first time, it considers that two breaches of the Sapin II Law have been identified, the Sanctions Commission is intended to be educational: rather than imposing a financial penalty, it enjoins the company to comply and to justify its actions. The Commission will decide at a later stage on the persistence of breaches in the light of the compliance measures implemented.

AFA Sanctions Commission, Decision No. 19-02 of 7 February 2020