Compliance in France

August Debouzy

August Debouzy advises an impressive client base consisting of many of France’s leading companies as well as several major multinationals. The practice assists with anti-corruption risk mapping and the setting up of compliance programmes. Lately, it has been advising a high number of clients facing French Anti-Corruption Agency (AFA)’s audits. Clients also increasingly solicit the team to advise on emerging issues such as business ethics, corporate governance and corporate duty of vigilance. Finally, the practice also demonstrates strength in advising on US and UK anti-corruption and bribery compliance systems, including the management of cross-border investigations led by US and UK agencies. The powerful team is co-headed by former Prime Minister Bernard Cazeneuve, Astrid Mignon Colombet and Benjamin van Gaver. Also highly recommended is counsel Olivier Attias.

Practice head(s):

Bernard Cazeneuve; Benjamin van Gaver; Astrid Mignon Colombet

Other key lawyers:

Olivier Attias

Clifford Chance

Clifford Chance assists a prominent client base with setting up and reviewing compliance programmes, especially on French anti-corruption and anti-bribery matters. The practice also assists with the conduct of internal investigations and acts for defendants in regulatory enforcement and criminal prosecutions led by one or multiple French and foreign authorities. Thomas Baudesson and Charles-Henri Boeringer are in charge.

Practice head(s):

Thomas Baudesson; Charles-Henri Boeringer

Testimonials

The team has good knowledge of all aspects of compliance work, including internal investigations, AFA control, litigation, negotiations (CJIP) with the authorities, international cooperation with foreign authorities or aspects of stock market communication.’

‘Charles-Henri Boeringer and his team are very up-to-date on this subject and provide us with an appreciable experience.’

‘Charles Henri Boeringer with whom I have dealt directly is certainly one of the top experts, if not the most recognised expert on the Paris market.’

Key clients

Airbus

Airbus

Teva Pharmaceuticals

L’Oréal

Dassault Systèmes

Savencia

Work highlights

  • Acting for Airbus in the resolution of its corruption case with the French enforcement authority, as part of the global resolution reached with the UK SFO and the US DoJ.
  • Advising Teva on the implementation of an internal process concerning lobbying regulations and on the gap analysis of their anti-bribery risk mapping process.
  • Advising L’Oréal on the implementation of an anti-corruption program imposed by the new law Sapin II and on updating the client’s anti-bribery risk map.

Herbert Smith Freehills LLP

Herbert Smith Freehills LLP impresses with its track record of assisting a high number of leading French companies with AFA-led audits, notably key players in the engineering, banking, water and insurance sectors. The practice is also particularly experienced in the conduct of internal investigations, notably carried out in the context of World Bank and other international development banks. Another area of strength is assistance with international sanctions, notably in relation to Iran and Russia. Jonathan Mattout is in charge. Also recommended is of counsel Raphaël CoeurquetinSergio Sorinas provides competition law compliance advice.

Practice head(s):

Jonathan Mattout

Other key lawyers:

Raphaël Coeurquetin; Sergio Sorinas

Testimonials

In-depth and practical knowledge of the Sapin II law.’

‘Jonathan Mattout provides excellent advice.’

Hughes Hubbard & Reed LLP

Hughes Hubbard & Reed LLP has traditionally been assisting leading French and foreign companies with US compliance and enforcement proceedings, often with the involvement of the Washington office. The Paris-based practice recently shifted its focus towards advising clients on French compliance issues, a successful adjustment as the high demand of assistance from many leading French companies in preparing and dealing with AFA-led audits demonstrates. The practice also has extensive experience in assisting clients with conducting internal investigations. The addition of white-collar crime and litigation expert Félix de Belloy in early 2020 (ex: Boken) nicely complements the group's existing strengths. The team’s knowledge spans French and international anti-corruption, whistleblowing, economic sanctions and anti-money laundering compliance and investigation work. Recently, the practice also assisted with upcoming trends such as social, environment, human rights and governance issues. Bryan Sillaman heads the team which includes Michael Huneke, Anne Gaustad, Nicolas Tollet  and counsel Olivier Dorgans.

Practice head(s):

Bryan Sillaman

Other key lawyers:

Michael Huneke; Anne Gaustad; Nicolas Tollet; Olivier Dorgans

Testimonials

‘The firm has one of the market’s oldest compliance practices. They have American partners living in Paris who have practiced the subject for much longer than their Parisian counterparts.’

 

Key clients

Airbus

Work highlights

  • Assisting Airbus with the resolution of criminal investigations by US, UK, and French authorities, which concerned the largest known anti-corruption financial penalty in the world.

White & Case LLP

White & Case LLP combines strong domestic expertise and international capabilities on anti-corruption compliance issues. The group's track record includes several leading banks and companies facing French AFA-led audits, assistance with the conduct of internal investigations in the context of corruption allegations, and due diligence audits of existing compliance systems in the context of M&A transactions led by the firm. Finally, the Paris white-collar and investigation team is also involved in several multi-jurisdictional investigations led by US, UK and French financial regulatory authorities. Ludovic Malgrain is in charge of the practice. Jean-Pierre Picca is another key member. Jean-Lou Salha, who was promoted partner in January 2021, is also highly involved.

Practice head(s):

Ludovic Malgrain

Other key lawyers:

Jean-Pierre Picca; Jean-Lou Salha

Testimonials

‘Impressive striking force; they were able to building a team quickly who was responsive and has excellent writing and analysing skills.’

‘Ludovic Malgrain and Jean-Lou Salha were excellent.’

‘Ludovic Malgrain and Jean-Lou Salha’s team is responsive, efficient and innovative.’

“The relationship is fluid; I can call them for specific questions and get their opinion very easily.’

Key clients

Oberthur Fiduciaire

Work highlights

  • Acting for several financial institutions and industrial groups in the context of administrative proceedings launched by the French Anticorruption Agency (AFA) as a consequence of the Sapin II law.
  • Representing an oligarch in criminal proceedings in France in relation to allegations of money laundering, tax fraud and misappropriation of corporate assets in France, Switzerland and Russia.
  • Advising an individual on criminal investigations in France in relation to allegations of money laundering and tax fraud.

Gide Loyrette Nouel A.A.R.P.I.

Gide Loyrette Nouel A.A.R.P.I. acts for leading companies, banks and financial institutions to assist with the setting up and reviewing of anti-corruption and anti-money laundering programmes. The team's experience spans guidance for clients facing AFA-led audits and the management of corruption and other whistle-blowing allegation crisis situations, often occurring overseas and requiring the conduct of internal investigations. The practice also advises financial institutions on banking and finance compliance.  The practice head group includes Bruno QuentinJean-Philippe Pons-Henry and Sophie Scemla as the key contacts, with banking and finance experts Jean-Guillaume de Tocqueville and Olivier Bernardi and competition compliance specialist Antoine Choffel also contributing.

Practice head(s):

Bruno Quentin; Jean-Philippe Pons-Henry; Sophie Scemla; Jean-Guillaume de Tocqueville; Olivier Bernardi; Antoine Choffel

Testimonials

‘Very responsive.’

Jones Day

Jones Day’s Bénédicte Graulle is the lawyer of choice for leading French and international companies seeking assistance with the setting up of anti-corruption programmes, including regarding Sapin II.  Other busy lines of work are assisting several clients facing AFA compliance audits and the management of sensitive whistle-blowing and other bribery and anti-corruption allegations, often pertaining to acts committed within foreign subsidiaries. The firm also provides assistance with product safety compliance through Françoise Labrousse and employment law compliance issues. Linda Hesse, Jean-Michel Bobillo and Emmanuelle Rivez-Domont are the other names to note.

Other key lawyers:

Bénédicte Graulle; Francoise Labrousse; Linda Hesse; Jean-Michel Bobillo; Emmanuelle Rivez-Domont

Mayer Brown

Mayer Brown assists many leading French and international corporations. The team demonstrates particular strength in handling cross-border matters, often collaborating with the firm’s international offices, and was appointed by leading companies and banks to assist with the establishment of worldwide compliance programmes, spanning duty of vigilance, anti-corruption and anti-money laundering aspects. Assistance for companies facing AFA and other foreign regulators' anti-corruption compliance audits is another key area. The team is increasingly retained by major French clients and banks and is experienced in advising on the conduct of internal investigations in the context of sensitive sanctions, embargo sanctions and money laundering accusations. Nicolette Kost De Sèvres is highly recommended. Counsel Joydeep Sengupta  also contributes.

Practice head(s):

Nicolette Kost De Sèvres

Other key lawyers:

Joydeep Sengupta

Testimonials

‘Good knowledge and experience of large cross-border investigations. The  practice has a good mix of US and local specialists. The lawyers are very personable; meaning I will enjoy working with them and have confidence that they have the skills and knowledge to get the work done.’

‘Counsel Joydeep Sengupta has a fantastic ability to drive cross-border investigations, establishing positive rapport with all stakeholders and getting the work done quickly and accurately.’

Key clients

B20/G20

Pegasystems

Theolex

Linkset

Red Cross (Croix Rouge Française)

Les Mousquetaires

Bourse Direct

Shopify

Elis

Kiwi Wealth

HSBC

Greenman

Société Générale

Work highlights

  • Advised fintech company Pegasystems on a number of issues, including the development of AML rules across 40 jurisdictions and the implementation of the 4th and 5th Anti-Money Laundering Directives in all EU countries.  
  • Representing Société Générale in connection with ongoing cross-border litigation concerning the Helms-Burton Act.
  • Advising Theolex, a French legaltech start-up on all aspects of its work, including product design, legal agreements with customers, and data analytics.

Norton Rose Fulbright

Norton Rose Fulbright ’s Christian Dargham is very experienced in assisting French and international companies with the setting up of compliance programs, spanning anti-corruption and whistle-blowing issues, and also provides key guidance on international sanctions. Recently, he also assisted several companies facing AFA compliance audits. Matters involving sensitive fraud and corruption allegations in relation to clients' activities in France and overseas, including in the conduct of internal investigations, are another area of strength. Also involved are Marta Giner Asins on competition and EU law compliance work, as well as Nadège Martin for data protection work.

Practice head(s):

Christian Dargham

Other key lawyers:

Marta Giner Asins; Nadège Martin

Quinn Emanuel Urquhart & Sullivan, LLP

Quinn Emanuel Urquhart & Sullivan, LLP’s dispute resolution team frequently assists leading companies with conducting internal investigations and compliance audits. The group is also well versed in handling judicial proceedings pertaining to international corruption and bribery accusations, with recent matters including assisting Renault with internal and international compliance issues in the context of the Carlos Ghosn case. Practice head Kami Haeri and counsel Valérie Munoz-Pons form a very experienced. duo. The announced hiring of Eric Russo, the first prosecutor from the French financial prosecution office (PNF) to join a law firm, at the end of 2020 made headlines and his arrival should further strengthen the practice.

Practice head(s):

Kami Haeri

Other key lawyers:

Valérie Munoz-Pons; Eric Russo

Testimonials

An expert team that provides tailored assistance.’

‘Valérie Munoz-Pons is highly available.’

Key clients

Renault

Work highlights

  • Advising Renault on the Carlos Ghosn case concerning internal and international compliance issues in the context of a large-scale investigation conducted not only in France but also in Japan, the US and the Netherlands.

Signature Litigation AARPI

Signature Litigation AARPI’s Nicolas Brooke has extensive experience in advising on compliance issues and dealing with international investigations. He is assisting many leading corporations by providing training assistance and reviewing and updating their Sapin II anti-corruption compliance programmes. AFA compliance audits are another busy line of work. Finally, he is also assisting companies, financial institutions and high-ranking executives with the management of sensitive cases concerning bribery and corruption allegations as well as companies’ international operations. Associate Camille Gravis provides strong support.

Practice head(s):

Nicolas Brooke

Other key lawyers:

Camille Gravis

Testimonials

‘Nicolas Brooke is a superb advocate with deep experience in the French market. Level-headed, thoughtful and creative; he is truly first rate.’

Key clients

Renault

Société Générale

MAN Trucks

Groupe Givaudan

Schneider Electric

Thales

Work highlights

  • Advising Renault on the French government inquiry into diesel emissions.

Allen & Overy LLP

Allen & Overy LLP advises banks and companies on the setting up and reviewing of anti-corruption (including Sapin II) and anti-bribery programmes. The dispute resolution team also has strong expertise in advising leading banks and financial institutions on anti-bribery and financial regulatory compliance and enforcement work. Denis Chemla and Dan Benguigui co-head the practice.

Practice head(s):

Denis Chemla; Dan Benguigui

Testimonials

Available, strong knowledge of procedures and of the banking and finance environment, excellent writing skills.’

Key clients

BNP Paribas

Crédit Suisse

Danske Bank

Deutsche Bank AG

Skandinaviska Enskilda Banken AB (SEB)

Suntory Group

Imperial Tobacco

UBS

Natixis / BPCE

Worldpay

Work highlights

  • Assisting the Suntory group with the creation of a new ABC compliance programme.
  • Advising the UBS group on a large-scale investigation led by the French criminal authorities in relation to allegations of laundering.  
  • Advising Imperial Tobacco on French compliance requirements and assisting the client with the amendment of its compliance programme.

Bougartchev Moyne Associés

Litigation boutique Bougartchev Moyne Associés advises major French banks and industrial companies as well as international groups on compliance reviews and investigations. The practice notably assists clients with audits conducted by various French anti-corruption, securities and banking regulators. Kiril Bougartchev and Emmanuel Moyne co-head the practice.

Practice head(s):

Kiril Bougartchev; Emmanuel Moyne

Bredin Prat

Bredin Prat advises leading French corporations on anti-corruption, anti-money laundering, whistle-blowing and duty of vigilance compliance issues. The practice assisted several companies facing French AFA’s audits and assisted Imerys and its former CEO before the  Enforcement Committee of the AFA, only the second case brought before the Enforcement Committee in France. White-collar crime lawyers Eric Dezeuze and Guillaume Pellegrin co-head the practice.

Practice head(s):

Eric Dezeuze; Guillaume Pellegrin

Work highlights

  • Acted for Imerys and its former CEO in connection with proceedings before the Enforcement Committee of the French anticorruption agency (AFA) where both were facing administrative fines and injunctions.

Cleary Gottlieb Steen & Hamilton

Drawing on its US capabilities and experience, Cleary Gottlieb Steen & Hamilton has been growing its Paris compliance practice. Led by the litigation team, the Paris office assists leading companies and banks with the setting up of domestic and international anti-corruption and anti-money laundering compliance programmes and related investigations. The group advises on internal investigations and also offers experience in investigations led by the World Bank. Other work includes US sanctions, French AFA-led investigations and  compliance due diligence in the context of the firm’s M&A transactions. Key names include counsel Guillaume de Rancourt and new hire Caroline Hailey who rejoined the firm as senior attorney after gaining first-hand compliance and monitoring experience at Total.

Practice head(s):

Guillaume de Rancourt; Caroline Hailey

Key clients

IDEMIA

BNP Paribas

Crédit Lyonnais (LCL)

HSBC Holdings

UBAF (Union de Banques Arabes et Françaises)

BNP Paribas

Royal Bank of Canada

The Baupost Group

Work highlights

  • Assisted Idemia with an investigation by the World Bank’s Integrity Vice-Presidency into allegations of corruption in relation to a Bangladeshi contract, together with related internal investigations, and successfully applied for a release from World Bank debarment following an overhaul of the group’s compliance program.  
  • Advising Alstom on the compliance and the World Bank investigation aspects of its €6.2bn acquisition of Bombardier Transportation.
  • Representing a manager of The Baupost Group before the Criminal Section of the Paris Court in connection with a tax fraud case involving tax and penalties in excess of €200m.

Cohen & Gresser LLP

Cohen & Gresser LLP is recommended for its strong expertise in assisting French and international companies and banks as well as CEOs and employees with financial compliance audits and investigations led by the French, UK and US agencies. The practice also assists high-ranking executives with cross-border securities investigations involving France and the US. Recently, the firm was particularly consulted on Brexit compliance issues. Additional data compliance expertise is also available. Muriel Goldberg-Darmon is in charge, with counsel Guillaume Guérin providing key support.

Practice head(s):

Muriel Goldberg-Darmon

Other key lawyers:

Guillaume Guérin

Testimonials

‘We are very satisfied with their services.’

‘Good availability, competence and pragmatic approach.’

Work highlights

  • Represented the former CEO of a listed French fashion company in connection with an AMF investigation and enforcement proceeding regarding potential market abuses and the lack of disclosure of financial transactions.

DLA Piper

Led by Fabien Ganivet, DLA Piper ’s team assists clients with the setting up and review of Sapin II and other vigilance and anti-money laundering regulation compliance programmes. The practice also provides assistance during crisis situations, such as conducting internal investigations. AFA compliance audits are a core part of the group's caseload.  Clients include leading French and international companies from a wide range of sectors, including life sciences, automotive and aviation. They benefit from the firm’s global capabilities. Counsel Sara Koski is a key member of the team.

Practice head(s):

Fabien Ganivet

Other key lawyers:

Sara Koski

Laurent Cohen-Tanugi Avocats

Boutique Laurent Cohen-Tanugi Avocats offers experience in the setting up of Sapin II compliance programmes in addition to experience in advising clients on investigations conducted by the US Department of Justice. Practice head Laurent Cohen-Tanugi  is highly experienced and has rare first-hand experience acting as a US Foreign Corrupt Practices Act (FCPA) monitor.

Practice head(s):

Laurent Cohen-Tanugi

Testimonials

‘Laurent Cohen-Tanugi Avocats is specialised in cross-border anti-corruption compliance and white-collar crime. Mr. Cohen-Tanugi has a unique track record of international legal practice experience, an in-house position in a big international group, and several state agencies’ appointments around the world, such as FCPA monitor. As a result, he can provide very specialised, yet practical advice in the area of anti-corruption and compliance’.

‘Me Cohen Tanugi is highly proficient in this field.’

Work highlights

  • Advising the French subsidiaries of a multinational food industry group on compliance issues, including their anti-corruption compliance programmes pursuant to Sapin II.
  • Advising as expert witness on French and European compliance best practices in an international arbitration involving one of the leading luxury groups in the world.
  • Acting as co-counsel in US criminal defence proceedings in connection with the French corporate executive of a financial institution.

Navacelle

Boutique firm Navacelle has particular expertise in assisting employees and companies with investigations carried out by French and international authorities, and especially the US authorities. The practice also assists with the conduct of internal investigations. Stéphane de Navacelle is in charge. Julie Zorrilla and Clémentine Duverne were promoted to partners in January 2020.

Practice head(s):

Stéphane de Navacelle

Other key lawyers:

Clémentine Duverne; Julie Zorrilla

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden, Arps, Slate, Meagher & Flom LLP regularly joins forces with the firm's key hubs in Washington DC and London to provide seamless cross-border service in high-profile matters. The practice is particularly sought after by leading French banks facing high-stakes international investigations from the US authorities. The practice notably assissted Société Générale with the setting up of strategic compliance programmes to be reviewed by AFA and the US Federal Reserve in the context of the recent settlements agreed by the bank with the US and French authorities concerning serious economic sanctions, corruption and market fraud allegations. The team also provides regular assistance to banks and companies on US sanctions, the French blocking status and anti-money laundering compliance. Jamie Boucher, who is mainly based in Washington, but also spends a significant amount of time in Paris, heads the firm's global practice. Also recommended is the Paris-based counsel Sidne Koenigsberg.

Practice head(s):

Sidne Koenigsberg

Other key lawyers:

Jamie Boucher

Testimonials

‘The Skadden team always listened to our needs, then delivered sound advice on time, argued with examples to allow us to apply their advice easily.’

 

Key clients

Société Générale

Crédit Agricole CIB (CACIB) and Crédit Agricole SA (CASA)

A major global payments company

UniCredit Bank Austria (Bank Austria)

A global association of companies and NGOs

Viagogo Entertainment Inc.

A French bank

A large German bank

A director of a Delaware company

French and European private banks

A German vehicle manufacturer

Crédit Agricole

A large Nordic Financial Institution

Work highlights

  • Advising Société Générale on its multi-year compliance enhancement programme related to obligations under the various agreements with French and US authorities entered into in 2018 as part of high-profile economic sanctions, corruption and civil and criminal settlements relating to market fraud.
  • Representing a major global payments company in a multi-jurisdictional voluntary internal investigation concerning the company’s compliance with US economic sanctions laws.
  • Advising a global financial institution headquartered in Northern Europe in connection with a high profile multi-jurisdictional, multi-agency regulatory investigation in the US and other jurisdictions, relating to allegations of money laundering in the Nordics, Baltics and beyond.

Taylor Wessing

Taylor Wessing's practice combines corporate, white-collar, employment, life sciences and competition law compliance expertise, spanning several jurisdictions thanks to its international network. The practice notably advises on anti-corruption compliance work and provides training assistance. A particularly busy line of work are matters for healthcare companies seeking assistance with anti-corruption and new industry-specific anti-gift regulations. The practice also assists companies with the compliance aspects of major international organisations, for example compliance with World Bank requirements. Competition, EU, trade, and compliance expert Evelyne Friedel and employment law expert Markus Asshoff are the key contacts. M&A partner Gilles Amsallem also contributes. Clients also benefit from the expertise of financial litigation expert and senior partner Paul-Albert Iweins and of corporate specialist Anne-Juliette de Zaluski.

Practice head(s):

Markus Asshoff; Evelyne Friedel; Gilles Amsallem

Other key lawyers:

Paul-Albert Iweins; Anne-Juliette de Zaluski