Paris Partner Constantin Achillas, Counsel David Père and Senior Associate Cécile Terret were interviewed Oct. 16 by Les Echos Executives regarding the initiation of the first investigations by the French Anti-corruption Agency by the end of the year for the companies in France which may not be in compliance with the obligations of the Law Sapin II. On this, David Père said, “Companies tend to think that they already comply with the new requirements. Nevertheless, to absolutely conform, they need to go beyond mere formalism and implement efficient prevention measures against the risks of corruption. One has to keep in mind that the criminal judge will in the end rule on the conformity of these measures.” Cécile Terret commented, “In the framework of the public consultation by the new Agency, the companies more likely to send their comments are those at an advanced-stage of implementation of their program. As these comments may doubtless create unsolicited interest by the anti-corruption instance, any submissions should be made through counsels.” So far the procedures remain unclear, as underlined by Constantin Achillas. “Investigations will take place at the headquarters of the company concerned, but the foreign subsidiaries of French groups will be also targeted,” he said. “And so far, we are not aware of the conditions under which these on-site inspections will be carried out. In case of an investigation, international coordination will be essential.” Click here to read the full article.