New French Anti-Corruption Law: French Parliament Adopts Law “Sapin 2” on Transparency, Fight Against Corruption and Modernization of the Economy

Sullivan & Cromwell LLP - December 21, 2016
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On December 10, 2016, French Law n° 2016-1691 (dated December 9, 2016) on anti-corruption measures (the “Law”, also known as “Sapin 2”) was published in the French Journal Officiel. The Law introduces substantial changes to French anti-corruption and transparency laws, in line with international efforts; in promulgating the Law, the French ministry of Treasury noted that France had previously been subject to criticism by the OECD and various NGOs in respect to its anti-corruption measures.
 
Among other things, the Law mandates French companies subject to its provisions to implement certain anti-corruption policies and procedures, training programs, whistleblower processes, risk-mapping, monitoring procedures and accounting controls to detect and prevent corrupt conduct.
 
This memorandum provides a high-level summary of certain key provisions of the Law relating to transparency and anti-corruption measures. Many provisions of the Law will be further supplemented by French governmental decrees.