Despite the efforts made by companies to comply with the
requirements of the Sapin 2 law, most anticorruption programs in
France remain qualitatively insufficient.
The French Anticorruption Agency ("FAA"), a national
regulatory authority created by Law 2016-1691 of December 9, 2016
("Sapin II law"), has just released its 2021 activity
report.
An analysis of the inspections the FAA carried out on economic
actors (i.e., companies in the private or competitive sector)
points to some key conclusions.
First, the FAA determined that there has
beenquantitativeprogress in the implementation of aspects
of corporate compliance programs consistent with FAA guidance. In
this regard, the FAA noted that of the 34 inspections it carried
out on its own initiative in 2021 concerning economic actors, 25
showed no breach of the obligation to implement and deploy the
compliance procedures and systems provided for in Article 17 of the
Sapin II law. The remaining nine inspections
