On 9th July, White & Case published the chapter it had prepared for Europe, Middle East and Africa Investigations Review 2019.  It discusses the continued effects of Sapin II (the law on transparency, corruption and modernisation of the economy) on anti-corruption, the new enforcement climate after Sapin II and the upcoming ‘blocking statute’ reform, as well as the duty of vigilance law (an an obligation on companies to prevent social, environmental and governance risks related to their operations that may also extend to the activities of their subsidiaries and business partners, subcontractors and suppliers). and other developments – including creation and use of a deferred prosecution agreement (CJIP) equivalent, whistleblowing, extending “name and shame” provisions to tax fraud.


This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

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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