French Authorities Publish Guide on Anti-Corruption Internal Investigations
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- On March 14, 2023, France’s main anti-corruption authorities published best practices for companies conducting anti-corruption internal investigations in France.
- Although it has no normative value, this document is generally helpful for companies that have to conduct internal investigations as part of their mandatory French-style compliance programs and those who conduct internal investigations in anticipation of a potential French-style deferred prosecution agreement.
- In this alert, we discuss what we consider to be the main aspects of these best practices (internal investigation procedures, collection of evidence, interviews, attorney-led internal investigations, attorney-client communications protection, cooperation with enforcement authorities). We have also added some comparisons and comments from a U.S. perspective.