Compliance
and Investigations

Any company with more than 500 employees and a turnover exceeding EUR 100 million must implement an anti-corruption compliance program under Article 17 of the Sapin II Act. In the event of non-compliance, the AFA sanctions committee may impose fines of up to EUR 200,000 for individuals and EUR 1 million for legal entities. We advise on every component of anti-corruption compliance: audits, risk mapping, design of tailored anti-corruption programs and preparation for AFA inspections. This comprehensive approach enables clients to anticipate risks, strengthen governance and ensure compliance with applicable regulations.

Companies in scope must identify, prevent and remedy adverse impacts of their activities on human rights and the environment throughout their value chain. The European CS3D Directive (EU) 2024/1760 provides for sanctions of up to 5% of worldwide net turnover in the event of non-compliance. We design robust vigilance plans integrating business ethics and social, environmental and governance issues across the entire supply chain, in compliance with national law and the CSRD and CS3D directives. We also represent companies before the competent courts when their vigilance frameworks are challenged.

International sanctions regimes and anti-money laundering and counter-terrorist financing (AML/CTF) requirements demand constant vigilance and tailored compliance frameworks. Non-compliance exposes the company to severe administrative, criminal and reputational sanctions. We advise on regulatory compliance with sanctions regimes (DGT, SBDU) and AML/CTF: risk assessments, due diligence reviews, internal policy drafting, staff training, internal investigations and oversight of corrective measures. Each framework is designed to be operational and adapted to the business realities of our clients.

Law No. 2022-401 of 21 March 2022, in force since 1 September 2022, strengthened whistleblower protection by broadening the definition of whistleblowers and simplifying reporting channels. Every alert received must be handled within a rigorous procedural framework; failure to do so can compromise the investigation’s integrity and expose the company to litigation. We intervene at each stage: receiving the alert, conducting the internal investigation, implementing corrective measures, integrating criminal, employment, commercial and compliance considerations. The goal is to ensure credible and legally secure investigations.

Integrating ESG and ethical standards into corporate governance now goes well beyond declarations: regulators, investors and business partners require operational and verifiable frameworks. We advise companies on structuring their ESG policies: drafting ethical charters, establishing dedicated committees, providing executive training, and managing reputational risk. We also intervene in the event of litigation or crisis involving social or environmental responsibility issues, defending the company’s interests while preserving its institutional credibility.

Anti-corruption, duty of vigilance, international sanctions, export controls, AML/CTF, internal investigations: each framework we design is operational, tailored to business realities and aligned with international best practices. Our lawyers have trained more than 600 clients from 400 companies and have participated in numerous forums at the OECD, the French Senate and leading professional organizations. We prepare companies for in-depth audits, design robust compliance frameworks and support executives and legal departments in crisis management. This experience shapes an approach that is both pragmatic and strategic.