Compliance and internal investigations
Compliance Programs (Sapin II; FCPA/UKBA; AML/CFT; Duty of Vigilance; Export Control)
- Risk mapping (corruption; influence peddling; illegal taking of interest; favoritism; fraud; conflicts of interest; AML/CFT; international sanctions);
- Whistleblower systems (implementation or compliance with the Waserman Act and Decree, and handling of alerts as an external service provider);
- Third-party due diligence procedures; KYC/KYS;
- Procedures for sales consultants;
- Acquisition or divestiture audits;
- Code of conduct, ethics charter;
- Structuring of governance bodies;
- Reviewing and drafting of protective contractual clauses;
- Training for at-risk personnel.
Internal investigations
- Corruption; fraud; embezzlement; misuse of corporate assets; harassment: development of investigation procedures;
- Interviews with witnesses and suspects;
- Collection and analysis of documentary evidence (in partnership with forensic specialists for digital evidence);
- Drafting of the investigation report.
Inspections by regulatory authorities (AFA; AMF; ACPR and DGCCRF)
- Responses to questionnaires;
- Collection and coordination of documentation submission both prior to and during the adversarial phase;
- Preparation for interviews;
- Representation before sanctions committees.
Crisis management
- Legal and strategic support in managing crisis situations;
- Development and implementation of appropriate internal and external communication strategies.
