On 16th August, Ropes & Gray LLP published an article saying that in June the French National Financial Prosecutor’s Office (PNF) and the French Anti-Corruption Agency (AFA) published joint guidelines on the relatively new corporate settlement mechanism in France known as a Judicial Public Interest Agreement, or Convention Judiciaire d’Intérêt Public (CJIP) – roughly the equivalent to deferred prosecution agreements in the US and UK.  This is the first time that the PNF and the AFA have issued joint guidelines on CJIP agreements.  The article notes that CJIP is a first of its kind in the French legal system, and that previously co-operation between French prosecutors and companies for the purpose of criminal settlements or plea agreements was non-existent in France.  The PNF-AFA CJIP Guidelines cover the following areas: conditions required to enter into a CJIP; the determination of fines; compliance programmes; international co-ordination; and compliance with the French blocking statute which prohibits persons from sharing information of an economic, commercial, industrial, financial or technical character with foreign authorities when doing so would affect or violate France’s essential economic interest.  After providing details under each of these headings, the article comments that, while the joint PNF-AFA guidelines are a welcome development, they are imprecise in many parts and do not offer much new insight on the CJIP mechanism that was not already addressed.  Nonetheless, it says, there are some takeaways worth noting, which it details.

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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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