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Pursuant to its mission under the Sapin 2 Act of December 9, 2016, the French Anticorruption Agency (AFA) released guidelines to help private and public sector entities prevent and detect corruption. Its first Guide released in February 2019 pertains to the governance of the anticorruption compliance function within private companies and provides a wealth of information as to the proper way in which an integrated and effective compliance function should be structured. This Guide gives valuable insights into the way in which the transversal compliance function should be articulated with other functions within the company and how it should fit into its organizational structure. It also provides guidance about the proper governance of this cross-functional endeavor.
In this presentation, Joanna M. Ritcey-Donohue of JRD Law PLLC (Washington, DC) and Albert Janet of HÉRÈS (Paris) will discuss:
- The appointment and positioning of the person in charge of anticorruption compliance, as well as the resources allocated to this function;
- The duties of the chief compliance officer (CCO), as regards the various policies and procedures to be implemented in companies subject to the provisions of the law (e.g. risk-mapping, code of conduct, training programs, whistleblower processes); and
- The profile and responsibility of the CCO.
Program Level: Update
Intended Audience: Legal, finance and compliance professionals responsible for advising clients on international matters
Advanced Preparation: None