U.S. and French Anti-Corruption Enforcement: FCPA, Sapin II, and Cross-Border Investigations

This CLE webinar will compare French and U.S. anti-corruption laws and enforcement approaches and examine the implications for multinational companies. The panel will discuss the U.S. Foreign Corrupt Practices Act (FCPA), French anti-corruption law and Sapin II compliance requirements, and practical approaches for managing corruption risk across both jurisdictions.

The U.S. and French legal frameworks and enforcement practices differ. In the United States, DOJ and SEC enforcement priorities shape how companies evaluate FCPA risks and address potential violations. In France, Sapin II requires covered companies to establish anti-corruption compliance programs. The French Anti-Corruption Agency monitors compliance with those requirements, while the National Financial Prosecutor's Office handles criminal corruption cases. These differences stand out when alleged misconduct impacts operations in both countries. Counsel must confront significant differences in how internal investigations are conducted, information is shared, and privilege is protected in the two jurisdictions.

Listen as our panel compares French and U.S. enforcement practices, discusses coordination among authorities in cross-border matters, and offers practical guidance for managing corruption risk, responding to potential misconduct, and aligning corporate compliance programs with the requirements of both jurisdictions.