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French Anti-Corruption Agency Issues Annual Report


Today’s post is from Paris-based Bryan Cave Leighton Paisner attorneys David Père, Ariane Dulcire and Cécile Terret.

The French Anti-Corruption Agency (AFA) was created by Law n°2016-1691 of 9 December 2016 known as the Sapin II Law. As part of its missions, Article 3 of the Law provides that it prepares an annual activity report that is made public. In these annual reports, the AFA sets out the actions, work and events it carried out during the past year, in accordance with the missions entrusted to it by the French legislator.

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French Minister Of Justice Releases Guidelines To Fight International Corporate Corruption


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


[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


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


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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