On January 12, 2021, the French Anti-Corruption Agency
(Agence Française Anticorruption, hereinafter
"AFA") published its new guidelines which will serve as
the reference framework for its investigations, effective from July
13, 2021.
These new guidelines, which are both more demanding and
pragmatic because they have been adapted to take into account the
inspections and audits carried out by the AFA since the entry into
force of the former guidelines, deserve, in our opinion, the full
attention of entities subject to Article 17 of the Sapin II Law
1.
Instead of the 8 measures of the Sapin II Law to which was added
the necessary involvement of the top management, the AFA structured
its new guidelines
2 around three inseparable pillars:
