Navigating French Internal Investigations and Self-Reporting Post-Sapin II
In the less than two years since Sapin II came into force, France has demonstrated its clear intention to become a key enforcer alongside the U.S. Department of Justice and the UK Serious Fraud Office. The Parquet National Financier, the lead French investigating and prosecuting agency, has entered into five deferred prosecution agreements (called Convention Judiciaire d’Intérêt Public (CJIP)) with companies. The French authorities have levied corporate fines comparable to, or in excess of, mature Western regulators.
Writing for Anti-Corruption Report, Dechert lawyers Matthew Cowie, Karen Coppens and Marie Perrault examine the benefits and the difficulties of cooperating with French authorities with a view to obtaining a CJIP, analyze issues faced by foreign advisors when working in a French environment including considerations for self-reporting in France and examine how France’s new approach to anti-corruption has led to French prosecutors working with other enforcement agencies in multi-jurisdictional cases.