France’s new anti-corruption law has been
heralded as a small revolution in the battle against white
collar crime. It also indicates a growth in French
extraterritoriality to rival the US and UK’s
treatment of corrupt practices.
On November 8 the French National Assembly adopted the
so-called Sapin 2 law, which requires large French companies
and groups to take measures to prevent and detect acts of
corruption and influence peddling committed in France or
The law applies to companies with at least 500 employees, or
belonging to a group of companies which has at least 500
employees and parent company headquarters in France; and having
a turnover, or consolidated group turnover, of more than
€100 million ($106 million). In-scope companies will be
required to establish a code of conduct to prevent corruption.
Failure to do so could lead to prosecution,...