The Agence Française Anti-Corruption (AFA) has recently taken action against two companies that violated the French Anti-Corruption Law, Sapin II. The AFA published two new Conventions Judiciaires d’Interêt Public (CJIPs), similar to American Deferred Prosecution Agreements (DPA), regarding corrupt payments.
As the first of their kind, these actions provide some insight into how CJIPs function, how penalties are assessed, the factors considered in determining penalties and how a monitorship “à la Française” may be structured for those companies caught making corrupt payments.
Xavier Oustalniol outlines the enforcement actions in a recent post for The FCPA Blog.
