Sapin 2 Act
The Sapin 2 Act (Law No. 2016-1691 of 9 December 2016) is the French legislation on transparency, anti-corruption, and modernisation of the economy. It requires large French companies to implement an anti-corruption compliance programme comprising eight mandatory pillars.
Adopted in 2016, the Sapin 2 Act represents a major advancement in the French anti-corruption framework. It established the French Anti-Corruption Agency (AFA), responsible for monitoring the quality and effectiveness of corporate compliance programmes. Companies with more than 500 employees and revenue exceeding 100 million euros are required to implement the eight preventive measures.
The eight pillars of the Sapin 2 Act include: a code of conduct, an internal whistleblowing system, a corruption risk mapping exercise, third-party due diligence procedures (customers, suppliers, intermediaries), accounting control procedures, a training programme, a disciplinary regime, and an internal monitoring and evaluation system. Verification of third-party identity and integrity is a central element of this framework.
The Sapin 2 Act also introduced the judicial convention of public interest (CJIP), a deferred prosecution agreement mechanism allowing companies to resolve corruption cases without trial. CheckFile.ai supports Sapin 2 compliance by facilitating document verification as part of third-party due diligence and customer identification processes.
Regulations
Real-world examples
- 1.A CAC 40 company implements a corruption risk mapping covering all its subsidiaries and business partners, in compliance with the Sapin 2 Act.
- 2.The French Anti-Corruption Agency (AFA) conducts a compliance audit at an industrial group and identifies gaps in the third-party evaluation process.
- 3.A company enters into a CJIP (deferred prosecution agreement) with the National Financial Prosecutor's Office for foreign bribery, committing to strengthen its compliance programme.