ARTICLE · 04 AUGUST 2026

First “Direct” Pecuniary Sanction Under Sapin II: Compliance Lessons From Decision 25-01 (Société V And MS)

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France's Anti-Corruption Agency has imposed its first direct financial penalties under the Sapin II Law on a holding company and its executive for failing to implement required corruption prevention measures, marking a significant shift in enforcement approach. The decision establishes that compliance deficiencies are assessed at the audit date rather than when remediation occurs, and that senior executives may face personal liability for non-compliance. What does this landmark ruling mean for multinational

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On July 9, 2026, the Sanctions Commission (“Commission”) of the French Anti-Corruption Agency (Agence française anticorruption) (“AFA”) issued Decision No. 25-01 (“Decision”), marking the first time since the anticorruption compliance obligations under Article 17 of the Sapin II Law (Law No. 2016-1691 of December 9, 2016) (“Sapin II Law”) took effect in June 2017 that the AFA has imposed direct financial penalties on a French holding company (“Company”) and one of its executives for failing to implement corruption prevention and detection measures, without first seeking an injunction.

The Decision confirms, among other things, that (i) the AFA may impose financial penalties without first pursuing an injunction; (ii) compliance deficiencies are assessed at the date of the AFA’s control, not the Commission’s decision; (iii) post-audit remediation, while relevant to sanctions, does not extinguish liability; and (iv) senior executives may incur personal financial liability where they had

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

First “Direct” Pecuniary Sanction Under Sapin II: Compliance Lessons From Decision 25-01 (Société V And MS)

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