Compliance

We assisted a leading automotive equipment supplier in managing an audit by the French Anti-Corruption Agency (AFA) and drafting responses to the AFA. Following this audit, we supported the client in implementing the AFA’s recommendations, including risk mapping, third-party evaluation procedures, and anti-corruption accounting controls.

We supported an industrial client in reviewing all international trade transactions in light of international economic sanctions and restrictive measures, as well as export control regulations. This review led to the revision of contracts and the establishment of risk assessment procedures for the transaction and involved parties.

In 2023, we assisted a client with an internal investigation following a report concerning misconduct in China. Our role was to provide legal assistance to the internal investigation team and to coordinate work with local lawyers, which involved developing an investigation strategy and organizing internal meetings and interviews.

We are assisting a French subsidiary with top management training sessions for 8 to 10 people. Together with the legal team, we have created a first training session dedicated to the fight against corruption, with practical cases based on the day-to-day life of operational staff (business gifts, conflicts of interest, intermediaries, whistleblowers, etc.), and a second on the prevention of anti-competitive practices (collusion, information sharing, abuse of dominance, etc.).

We assisted a client in deploying and implementing an internal whistleblowing system. This included:

• Drafting a new internal whistleblowing procedure to ensure legal and regulatory compliance,
• Managing the internal whistleblowing line, including receiving and processing reports,
• Conducting an internal investigation to corroborate the facts reported through whistleblowing.

We advised an international cement company on the application of international economic sanctions and restrictive measures (adopted by the EU, US, and Switzerland) to a past transaction. We proposed corrective measures and policies and assisted in drafting the company’s CSRD.

We provide ongoing support to a client by analyzing planned transactions in light of international economic sanctions and export control regulations. We also assist in strengthening group-wide measures to ensure compliance with these regulations.

We assist a domiciliation company in implementing its obligations under AML/CTF regulations, including:

• Deploying and updating an AML/CTF compliance program in line with the French Monetary and Financial Code,
• Analyzing and managing complex business arrangements presenting significant AML/CTF risks,
• Liaising with authorities, particularly during inspections by the DGCCRF and proceedings before the National Sanctions Commission.

Since 2023, we have been conducting a comprehensive mission for an international industrial group to prevent and manage criminal risks. This includes:

• Mapping criminal risks across the group (first phase completed),
• Drafting memoranda and policies on potential authorities’ interventions and investigation management,
• Reviewing delegations of authority (ongoing),
• Implementing measures to prevent criminal risk (ongoing).

We assisted a semiconductor manufacturer in responding to an NGO-issued formal notice concerning its 2022 Vigilance Plan and in drafting the 2023 Vigilance Plan in accordance with the requirements of the French Duty of Vigilance Law. Our work included:

• Drafting a response to the formal notice, addressing the allegations made by NGOs,
• Collaborating with the client’s team to develop the 2023 Vigilance Plan in compliance with the French Duty of Vigilance Law, including content and methodology for drafting the Vigilance Plan (including risk mapping), analysis and research on related topics, review and modification of various versions of the Vigilance Plan,
• Reviewing and revising the client’s internal whistleblowing system to ensure compliance with Vigilance Law requirements.