Webinar | The AFA’s meeting dedicated to monitoring companies’ anti-corruption measures
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Veil Jourde’s lawyers took part in a webinar on the first edition of the Rendez-vous de l’AFA devoted to the monitoring of corporate anti-corruption measures.
Isabelle Jegouzo, Director of the French Anti-Corruption Agency (AFA), shared some of the key findings:
- Shortcomings frequently identified during inspections: the absence of a register of gifts and a lack of control and a posteriori internal audit of gifts and invitations, which are essential for preventing and detecting the risks of corruption.
- Private corruption on the rise: increasingly committed by criminal groups and foreign interference, targeting employees of major groups in particular.
- Healthcare, a sector under surveillance in 2025: a wave of checks will target pharmaceutical companies to verify their compliance with legal obligations in terms of preventing and detecting breaches of probity. This initiative illustrates the AFA’s desire to strengthen the links between public and private sector controls.
- Sapin 2 Law and foreign subsidiaries: Isabelle Jegouzo reminded the meeting that subsidiaries of foreign groups established in France, as long as they exceed the defined thresholds, are fully subject to the obligations of the Sapin 2 Law in terms of preventing and detecting corruption.
- Tighter controls in all sectors: the number of reports doubles every year (200 received in January 2025), reflecting increased vigilance and tighter controls, including outside the healthcare sector.
Frequent use of Article 40 of the Code of Criminal Procedure:
- The French Anti-Corruption Agency regularly reports cases to the Public Prosecutor, particularly during inspections of public bodies. Several cases have been tried following reports made under this article.
- The majority of Article 40 cases are the result of reports received by the AFA, which examines them carefully before passing them on if the facts are sufficiently substantiated.
- AFA is also involved in audits as part of the conclusion of CJIPs (judicial agreements in the public interest).