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ARTICLE · 31 MAY 2022

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Publication By The French Competition Authority Of A New Framework Document On Competition Compliance Programs

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Ten years after its initial publication, and following a public consultation at the end of last year, the French Competition Authority ("FCA") on 24 May 2022 published a largely overhauled version of its...

FranceAntitrust/Competition Law
Nathalie Jalabert-Doury
Nathalie Jalabert-Doury
Jean-Maxime Blutel
Jean-Maxime Blutel
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Ten years after its initial publication, and following a public consultation at the end of last year, the French Competition Authority (“FCA”) on 24 May 2022 published a largely overhauled version of its framework document on compliance programmes.

In this document, the FCA recalls the virtues it sees in the adoption of such programmes: protection of competition, risk prevention and detection of possible cases of non-compliance.

However, since the adoption by the FCA of a Notice on the settlement procedure and compliance programmes in October 2017, there is no longer any question of reducing financial penalties for undertakings committing to this path. Unsurprisingly, the new framework document therefore does not provide for a reduction in fines or any other form of incentive for undertakings that adopt such a programme.

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