France’s new Sapin-II

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France’s new Sapin-II anti-corruption law 

Recommendations for French companies operating in the CIS

No country in the modern world is totally free from corruption. As a result, more and more countries are choosing to strengthen their anti-corruption legislation.

The business community is involved in this process as well. In the past, the Deloitte Forensic team’s projects have primarily consisted of corporate investigation engagements. Today, however, clients are increasingly asking us to assist them in verifying their employees’ compliance with applicable anti-corruption laws.

France has also embarked on the path of strengthening its anti-corruption regulations, as shown by the new Sapin-II law, which is aimed at fighting corruption and bribery both within France and overseas.

Indeed, the enactment of this new law is no accident, particularly with three French companies among the top 10 organizations that paid the largest fines to U.S. regulators for 2016 under the U.S. Foreign Corrupt Practices Act (FCPA).

Effective 1 June 2017, Sapin-II mandates that the presidents, directors and managers of French companies implement a set of measures aimed at preventing corruption and bribery. Under the new law, non-compliance with these requirements may be punishable by fines of up to EUR 200,000 for corporate officers and EUR 1m for legal entities.

So, how should French companies proceed in complying with these new regulations if they operate in the CIS, a region with an ever-changing business environment and high levels of corruption, and where corporate expansion requires working with intermediaries?

We will be answering this question on the following pages by taking a thorough look at  But, first, let’s consider the anti-corruption the anti-corruption measures mandated by Sapin-II, particularly through the lens of Deloitte Forensic’s experience in the CIS.

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