The Enforcement Committee of the French Anticorruption Agency
("FAA") handed down its first decision on July 4, 2019.
The decision follows the Agency's three-month audit (October to
December 2017) of the involved company's compliance
program.
The FAA brought the case to the Enforcement Committee, asserting
that the company's compliance program did not meet the
requirements set forth in France's landmark anticorruption
legislation, referred to as the Sapin II Law. In its long-awaited
decision, however, the Enforcement Committee concluded that the
company did not violate the provisions of the Sapin II Law.
Extensive Powers of the FAA
Before ruling on the merits of the case, the Enforcement
Committee confirmed that the FAA may require that a company under
audit disclose any "useful" documents and information,
including documents and information predating the effective date of
article 17 of the Sapin II Law—June 1, 2017. The Enforcement
Committee also confirmed that
