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French Minister Of Justice Releases Guidelines To Fight International Corporate Corruption

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A guest post today from Paris-based Bryan Cave Leighton Paisner attorneys Cécile Terret and David Père.

On 2 June 2020, French Minister of Justice Nicole Belloubet released guidelines to prosecutors setting out the contours of French criminal policy regarding international corruption (the “Note”). This Note recalls the major role to be played by the National Financial Prosecutor’s Office (PNF) and then presents the principles that should guide legal action and sanctions.

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Stock Option Grants For Doctors Results In FCPA Enforcement Action

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[This post is part of a periodic series regarding “old” FCPA enforcement actions]

In March 2005, the DOJ announced that Micrus (a medical device company based in California) agreed to non-prosecution agreement and to pay a $450,000 criminal penalty to resolve its Foreign Corrupt Practices Act liability. The conduct at issue largely focused on stock option grants provided to physicians at publicly owned and operated hospitals in France, Turkey, Spain, and Germany.

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A Look At The French Enforcement Action Against Airbus

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Previous posts here and here looked at the U.S. Foreign Corrupt Practices Act enforcement action against Airbus.

This previous post looked at the U.K. Bribery Act enforcement action against Airbus.

This post completes the enforcement trilogy, bylooking at the French enforcement action against Airbus.

Like the prior U.S. and U.K. bribery enforcement action, the French enforcement action against Airbus (see here for the Judicial Public Interest Agreement) focused on the use of business partners in connection with sales or attempted sales in various countries.

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Corruption: The French National Financial Prosecutor Signed His Fifth Judicial Public Interest Agreement

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A guest post today from Paris-based Bryan Cave Leighton Paisner attorneys Cécile Terret, David Père and Perrine Ader.

Recently, the French company Egis Avia, a subsidiary of the Egis group, agreed to pay a fine of €2.6 million to end the proceedings for corruption in connection with a contract to modernise the airport in Oran, Algeria. The fine was negotiated with the National Financial Prosecutor (the “NPF”) under a French legal instrument, namely the Convention Judiciaire d’Interêt Public (Judicial Public Interest Agreement; the “CJIP”).

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French Authorities Release New Guidelines For Settlement Agreements In Corporate Prosecutions

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Today’s post is from Cecile Terret and David Pere (attorneys with Bryan Cave Leighton Paisner in Paris).

On June 27, 2019, the French financial prosecutor (Procureur de la République Financier – PRF) and the French Anti-Corruption Agency (Agence française anticorruption – AFA) published new 18-page guidelines about an alternative system to corporate prosecutions which dates back to 2016. (See here).

These guidelines specify the conditions of application of the anti-corruption law known as “Sapin II”, adopted by France in 2016, which provides the possibility for the PRF, as an alternative to prosecution, to enter into a settlement agreement (known in French as the “Convention Judiciaire d’Intérêt Public”, – CJIP).

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