Compliance in France
Clifford Chance advises leading French and international corporations on the setting up of Sapin II anti-corruption and anti-bribery compliance programmes, and also offers guidance on risk assessment. The firm has been assisting many high-profile clients facing French Anti-corruption Agency (AFA)-led controls and assisted them with internal investigations regarding corruption and other accusations. The practice is playing a front part in the groundbreaking Airbus corruption domestic and international investigation case. EU and competition compliance and investigation expertise are further strengths of the team. Thomas Baudesson and Charles-Henri Boeringer are the key contacts. Associates Sophie Levy and Rachel Scott also deserve a mention.
‘Clifford Chance is recognised for its strong expertise in advising large companies in dealing with complex compliance issues. It is a state-of-the-art law firm able to provide different specialists with excellent skills and knowledge available at any time for their clients.’
‘The firm provides exceptional client service, is extremely professional, and always gives the impression of being calm in difficult situations, and unflustered.’
‘Thomas Baudesson has very extensive experience in French regulatory enforcement matters. His deep knowledge and excellent intuition make him very reassuring to work with.’
‘Charles-Henri Boeringer is a very dedicated and smart young partner, very familiar with AFA investigations. He is extremely knowledgeable, offers clear, straightforward and pragmatic advice. He is hard-working, prompt to respond, hands-on and reliable. He is able to think outside of the box.’
‘Associate Sophie Lévy demonstrates a positive can-do attitude and is a great team worker.’
‘Associate Rachel Scott is super efficient and produces excellent quality work.’
- Conducting the largest ever lawyer-led investigation of Airbus company over allegation of international corruption involving the French Parquet National Financier, the US Department of Justice and the UK Serious Fraud office.
Herbert Smith Freehills LLP
Herbert Smith Freehills LLP advises on compliance, investigations and corruption issues. The firm is advising many CAC 40 and other leading companies on the setting up of anti-corruption programmes. It is also assisting several clients facing AFA-led compliance controls and was recently involved in a landmark case for client Sonepar which it successfully defended in AFA’s first enforcement committee proceedings. The firm also advises on international sanctions and money laundering compliance issues, and conducts internal investigations. It is able to manage matters and crisis situations spanning several jurisdictions. Jonathan Mattout is highly recommended, and ably supported by of counsel Raphaël Coeurquetin. Sergio Sorinas provides competition compliance advice.
Other key lawyers:
‘An extremely capable team which has worked on several multi-jurisdictional investigations and understands the complexity of issues very well. They are extremely responsive and have a very strong bench of associates.’
‘The team is one of the very few on the Paris scene that truly has compliance expertise and experience. It has knowledge of codes of conduct and ethics policies, risk management and internal control environments.’
‘The team is fully dedicated and responsive, continuously at its client’s side, to provide appropriate recommendations in a timely manner.’
‘Jonathan Mattout and Raphaël Coeurquetin are top-notch attorneys, ones of the few that really master compliance and Sapin II requirements. They are discrete, yet hard-working and successful lawyers who always make the extra step to protect and defend their clients.’
‘Jonathan Mattout is extremely articulate and a lawyer who truly cares for his client’s interests in situations where a lot is at stake. He is extremely knowledgeable, especially on complex issues. His measured judgement, strategic sense and extensive experience distinguish him.’
- Successfully advised Sonepar before the French Anti-Corruption Agency (AFA).
Hughes Hubbard & Reed LLP is assisting many leading French corporations in the setting up of domestic and worldwide compliance programmes and on the review of risk assessment and sanction issues. The firm also recently assisted several companies facing AFA-led controls. In addition, the practice also stands out by its leading US and international capabilities which makes it a go-to-firm for high-stake multi-jurisdictional compliance and government agency-led investigations. It is notably assisting Airbus in facing combined FR, US and UK investigations for alleged acts of corruption. Paris-based partners Bryan Sillaman, Michael Huneke, newly appointed partner Nicolas Tollet and counsel Olivier Dorgans are the key names to note.
‘The practice is very comprehensive and does a great job. They have a lot of experience on the US side that they can translate into the growing French context.’
‘The team has in-depth knowledge of compliance issues. It provides great guidance to companies to set up well-adapted and thorough compliance programmes in a short period of time.’
‘Nicolas Tollet has great knowledge of compliance issues, is available, shows great listening skills and strong analysis skills. He is an excellent guide who provides great assistance to go through crisis situations or complex matters.’
- Represented Airbus in its response to parallel criminal investigations conducted in France, the UK, and the US.
White & Case LLP is assisting several leading French corporation facing AFA-led compliance controls. The Paris office, which often collaborates with Washington and Brussels-based colleagues, also advises on the setting up and reviewing of French, US and EU and other sets of anti-corruption and compliance rules. It is assisting clients in conducting internal investigations, including domestic investigations and investigations led by international government agencies, with a particular focus on proceedings conducted in the US. It is also advising a client with compliance reviews conducted by US monitors. Several leading banks are clients. Ludovic Malgrain and Jean-Pierre Picca are the key contacts.
BNP Paribas Group
Crédit Agricole Group
August Debouzy is instructed by many of France’s leading companies as well as blue-chip international corporations. The firm has strong expertise in compliance audits and risk mapping, in particularly in relation to Sapin II law anti-corruption provisions. It is also assisting several companies facing controls from the French Anti-corruption Agency and advises clients on a large set of other compliance rules, such as duty of care, GDPR data privacy and international sanctions. Former Prime Minister Bernard Cazeneuve and Benjamin van Gaver co-head the practice. Counsel Olivier Attias is also a key member. In December 2019, the firm announced the hire of Astrid Mignon Colombet from Soulez Larivière Avocats who is a very strong name in the field.
Litigation boutique Bougartchev Moyne Associés serves many leading French banks and industrial, defence and aerospace companies, but also attracts international groups. The 11-lawyer practice advises on compliance issues and provides assistance during audits conducted by various French anti-corruption, securities and banking regulators. The firm recently assisted a client facing a French Anti-corruption Agency-led compliance control, and helped clients in conducting training programs and internal investigations. It notably provides guidance on how to best protect professional secrets during regulator-led audits. Finally, the firm is retained to advise on anti-corruption M&A due diligence. Co-heads Kiril Bougartchev and Emmanuel Moyne are ably supported by associate Nathan Morin.
Cohen & Gresser LLP has leading expertise advising on banking, securities and stock market compliance and investigation work. Headed by Muriel Goldberg-Darmon, the firms advises financial services companies and banks. It also assists high-ranking executives in cross-border securities investigations involving France and the US. Recently, the firm was increasingly active on Brexit-related compliance issues. Counsel Guillaume Guérin is also recommended. Lara Kroop Delamarre left the firm for an in-house position at Danone.
Other key lawyers:
Gide Loyrette Nouel A.A.R.P.I. advises leading companies as well as leading banks and financial institutions on the setting up of anti-corruption, anti-bribery and anti-money laundering compliance programmes. The firm is also consulted on sensitive issues such as international sanctions and assists clients facing audits and investigations from France’s anti-corruption, competition, banking and financial markets regulators. Bruno Quentin, Jean-Philippe Pons-Henry and new experienced recruit Sophie Scemla who joined in 2019 from Eversheds Sutherland (France) LLP co-head the practice together. Also involved are competition partner Antoine Choffel, and banking and finance experts Jean-Guillaume de Tocqueville and Olivier Bernardi.
‘The highly able Sophie Scemla has unique mixed criminal defense and compliance background experience, wrapped up within a global reach and network capabilities.’
‘Olivier Bernardi and senior counsel Benjamin Delaunay show great availability, knowledge and thinking ability that enable clients to build innovative investment solutions in compliance with regulators and MiFID II’s requirements.’
Jones Day advises leading companies on the setting up of Sapin II anti-corruption programmes. Through Bénédicte Graulle, the firm regularly assists clients in conducting internal investigations following crisis situations or in the context of French or foreign judicial investigations. The firm also provides guidance on US and EU sanctions issues and offers complementary compliance expertise in relation to environmental law, employment law and health and safety issues.
Kramer Levin Naftalis & Frankel LLP
Kramer Levin Naftalis & Frankel LLP is appointed by banks and leading French private and public sector companies to advise on compliance and risk management issues in relation to the Sapin II, the Foreign Corrupt Practices Act, and the UK Bribery Act legislations. The firm also assists clients with sensitive issues such as duty of vigilance, the protection of trade secrets, EU grants and GDPR data privacy matters. Noëlle Lenoir’s expertise is highly sought after as her instruction by Airbus to review the companie’s compliance procedures in the context of the company’s current French, UK and US multi-jurisdictional investigations attests. Gilles Kolifrath and Hubert de Vauplane are also recommended.
- Advised Airbus on its compliance programme.
Seven-lawyer boutique firm Navacelle is particularly experienced in assisting foreign and domestic clients with investigations carried out by French and international authorities (including US Department of Justice, the US Securities and Exchange Commission, the UK Serious Fraud Office and the UK Financial Conduct Authority investigations). Stéphane de Navacelle is regularly appointed by companies to conduct internal investigations following suspicions of acts of corruption or other allegations. He is also regularly retained to monitor the implementation of compliance rules within companies following agreements reached with the World Bank and provides guidance on anti-corruption and anti-money laundering rules.
Norton Rose Fulbright advises many CAC 40 and other leading French companies as well as international corporations. The firm was recently often solicited to advise on the conducting of internal investigations regarding various accusations, including corruption and fraud allegations. The team also assisted clients with ivnestigations led by the French Anti-Corruption Agency or by the World Bank. Sanction issues are another area of strength. Christian Dargham is in charge. Also involved are Marta Giner Asins for competition and EU compliance issues and Nadège Martin for data protection compliance.
‘The team is very knowledgeable, very swift and extremely professional.’
‘The team shows excellent technique, is practical and able to provide great support to go through sensitive issues.’
‘Christian Dargham is easily reachable and very professional. He is a remarkable technician who leads his team in an efficient and inspiring manner. He always aims to provide complete and comforting support to clients.’
Quinn Emanuel Urquhart & Sullivan, LLP
Quinn Emanuel Urquhart & Sullivan, LLP's litigation and white-collar crime eight-lawyer team has strong expertise on international corruption issues. The firm notably advises high-profile companies specialising in the military and aerospace industries. It assists clients with training, the setting up of compliance programmes and with domestic and international investigations following corruption allegations. The practice recently assisted a major French company with an AFA-led audit. Practice head Kami Haeri and counsel Valérie Munoz-Pons are recommended.
Other key lawyers:
‘Kami Haeri is very good and gets the job done.’
Few months after opening its Paris office at the beginning of 2019, UK firm Signature Litigation AARPI attracted Nicolas Brooke to its bench. Brooke joined from a general counsel position at Société Générale where he earned a wealth of experience overseeing groundbreaking international and domestic investigations targeting the bank, notably playing a key role in reaching a settlement for his bank in the LIBOR case with the French, US and Japanese authorities and the European Commission. Brooke further managed a landmark case regarding corruption of Libyan public officials which led to simultaneous settlements with the US Department of Justice and the French Parquet National Financier. Brooke's unique experience is now highly sought after by companies and individuals seeking to set up compliance programmes or assistance with domestic and international investigations.
‘Nicolas Brooke has outstanding professional skills and shows a good sense of strategy. His previous experience as general counsel led him to play a key role in the negotiations of multi-jurisdictional settlements with prosecution authorities; he thus perfectly knows the international investigations environment.’
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP has strong global capabilities thanks to its integrated cross-border Paris-London-Washington practice whose members regularly split their time between the different offices. The firm offers extensive experience in representing many of France's leading banks in high-stake multi-jurisdictional regulator-led investigations, notably involving US, UK and French regulators. The practice recently assisted Société Générale with the negotiation of two multi-billion dollar settlements involving the US and French authorities in relation to economic sanctions, corruption and market-fraud accusations. Additionally, the group provides key guidance on the setting up of global and domestic compliance programmes on various issues, such as anti-money laundering, anti-corruption and international sanctions issues. Jamie Boucher , who is mainly based in Washington DC, but also spends a high amount of time in Paris, heads the firm's global practice. Also recommended are Paris-based counsels Sidne Koenigsberg and Valentin Autret, a litigation specialist.
‘ The practice is very knowledgeable and client-oriented.’
‘The team is always professional and responsive.’
‘A great team in which all individuals bring their best to the table.’
Credit Agricole CIB
UniCredit Bank Austria
- Represented Société Générale in settling three high-profile economic sanctions, corruption and market-fraud investigations involving French and US authorities.
- Advising CACIB and its parent CASA on their ongoing obligations under the terms of various settlement agreements reached in October 2015 with the US authorities.
Baker McKenzie's compliance and investigation practice is led by Eric Lasry. The practice advises CAC 40 and other leading French and international corporations from various sectors, including the industrial, luxury goods and transport sectors. The implementation of Sapin II anti-corruption programmes and audits led by the French Anti-corruption Agency are core aras of expertise. The practice is retained by clients to assist with conducting internal investigations, including the coordination of multi-jurisdictional internal investigations linked to corruption and international sanctions issues. The team is also solicited to perform the due diligence during M&A transactions, spanning French, UK and US compliance aspects. The firm's worldwide capabilities are a significant asset which led the practice to grew its portfolio with new major French clients. The arrival of new associate Blanche Balian from leading criminal law boutique Huc-Morel Labrousse Associés further enhanced the practice.
‘The firm is able to provide a wide range of expertise across many jurisdictions.’
‘The team is available, responsive, listens to its clients and provides practical advice.’
‘Eric Lasry and his team have the necessary skills and provide efficient and bespoke solutions while also taking into account local and cultural peculiarities.’
Bryan Cave Leighton Paisner LLP
Bryan Cave Leighton Paisner LLP advises companies and banks on Sapin II anti-corruption, EU and US sanctions, data issues, as well as on US anti-corruption and UK bribery compliance issues. The firm is also assisting an employee in the context of internal investigations being conducted on its company. Contantin Achillas heads the practice. Senior counsel Joseph Smallhoover, as well as counsels Cécile Terret, David Père and Sarah Delon-Bouquet also contribute.
Dentons’s Aurélien Chardeau advises leading French and international companies on the setting up of anti-corruption programmes, and provides guidance on international sanctions issues. Chardeau recently led an international team of lawyers in establishing a compliance programme spanning more than 50 countries for a leading company. He also assists companies with the conduct of internal investigations.
DLA Piper ’s Fabien Ganivet heads a seven-lawyer team which advises CAC 40 companies and other leading corporations on the setting up of national and multi-jurisdictional compliance programmes, including providing guidance on anti-corruption and vigilance issues. Ganivet also assists companies in conducting internal investigations.
‘Fabien Ganivet has outstanding professional skills and, as a previous prosecutor, he is very thorough and efficient.’
Guillemin Flichy's Thibault Guillemin advises companies and corporate executives on regulatory, ethics, governance and compliance issues. He notably helped a major French company with the setting up of an anti-corruption programme for the whole group. He also provides guidance in the context of M&A and joint venture transactions.
Laurent Cohen-Tanugi Avocats
Independent boutique firm Laurent Cohen-Tanugi Avocats advises companies on anti-corruption compliance programmes. The practice recently defended an individual facing investigations by the US Department of Justice. practice head Laurent Cohen-Tanugi also has first-hand experience in handling monitorship instructions for US enforcement authorities and the World Bank.
Mayer Brown hired international partner Nicolette Kost de Sèvres from DLA Piper LLP (US) to set up and head its compliance practice. A member of the Paris, Quebec, California and Washington bars, Kost de Sèvres has extensive experience gained notably from previous roles as in-house lawyer. She is in charge of a team whose expertise spans anti-corruption, anti-money laundering, data protection, securities and financial services compliance. The team works on the setting up of compliance programmes and also assists clients during investigations from domestic and international regulators. Major French and international companies and banks are clients.
Taylor Wessing provides assistance with the setting up of Sapin II anti-corruption programmes to French and international companies. The firm also assists many pharmaceutical laboratories in dealing with specific industry-sector anti-gift and health compliance regulations. Litigator Paul-Albert Iweins, employment law partner Markus Asshoff and competition law and health sector specialist Evelyne Friedel all contribute.
VIGO Cabinet d'Avocats
VIGO Cabinet d'Avocats' Emmanuel Daoud assists major French companies as well as local public law entities and several international groups on the setting up of Sapin II anti-corruption programmes. He also advises on whistleblowing, ethics and GDPR data compliance issues.