On 8th July, Clifford Chance published a briefing saying that, on 21st June, the Agence Française Anticorruption (AFA), the French anti-corruption agency in charge of monitoring corporate compliance programmes published its annual report providing key figures on audits conducted in 2018.  Clifford Chance says that while the first annual report in 2018 provided only high-level information, this second report gives a good overview of the AFA’s expectations of anti-bribery programmes.  The report says that 47 audits were undertaken, including 4 as part of the enforcement of conventions judiciaires d’intérêt public (French-style deferred prosecutions agreement).  The AFA has received 303 alerts about suspicions of corruption, influence peddling or non-compliance with obligations set by Article 17 of the Sapin II Law.  The report highlights the deficiencies emphasised by the AFA.


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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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