France

The Loi Sapin II (Act No. 2016-1691) is the leading anti-corruption extraterritorial legislation of France that aims to help identify and prevent bribery, influence-peddling activities, and corporate misconducts. It is applicable to corporations operating in France, having no less than 500 employees, and gross annual revenues of over €100 million. Article 17 of the law establishes the obligation to establish a corporate compliance program under 8 principles, which include developing a corporate code of conduct, risk mapping, due diligence of third parties, whistleblower program, and anti-corruption training. Non-compliance with the Loi Sapin II Act may incur administrative penalties not exceeding €1 million for corporations, executives, and the establishment of judicial compliance program.