French Anti-Corruption Agency (“AFA”) Control

The AFA monitors the measures taken by the entities subjected to its control in order to combat breaches of probity. In the event of non-compliance, the AFA may impose sanctions on the monitored entities.

In order to prevent and detect breaches of probity such as corruption, unlawful taking of interest or influence peddling, the entities above certain thresholds as defined by Sapin 2 Law are required to implement appropriate measures (code of conduct, risk mapping, internal alert/reporting procedure, third party evaluation procedures, accounting control procedures, training system, disciplinary procedure, control and evaluation system of the measures implemented).

The AFA has the authority to control the existence, and the effectiveness of the anti-corruption compliance mechanisms implemented, and to monitor judicial measures such provided under CJIP (similar to deferred prosecution agreements) as compliance program monitoring.

The control may then result in a warning or a referral to the Enforcement Committee.

The Enforcement Committee may decide to issue an injunction to correct compliance procedures, a financial penalty for individuals and legal entities, or the publication of the sanction decision.

Your challenges Our way Clients stories

Your challenges

Conducting an audit within a company requires anticipating the AFA's requests, responding to them and sometimes defending the company against the alleged breaches.

Anticipate AFA’s controls

To carry out its control, the AFA may require the company to provide a large amount of information. Anticipating the various stages of the audit procedure is therefore essential in order to prepare for this communication.

Adress AFA’s requests

A thorough knowledge of the anti-corruption system and the process of integrating it into the company is necessary in order to be able to answer the AFA's enquiries.

Defense in the event of an AFA sanction procedure

The AFA allows the audited companies to defend themselves during both the pre-litigation and litigation phases by giving them the opportunity to make observations and to challenge adverse decisions.

Our way

Personalized and effective assistance at every stage of the AFA controls and inspections

A thorough knowledge of AFA’s requirements and the stages of the control procedure

Our team has a thorough knowledge of the control procedure carried out by the AFA, whether on its own initiative or as part of the enforcement of judicial measures. Our lawyers advise clients on the best strategy to adopt at each stage of the procedure.

A thorough knowledge of the sanction procedure

We assist our clients facing sanction proceedings in shaping the best defense strategy and advise them on the available remedies.

Support throughout the compliance process required by the judicial authorities

Our lawyers support clients throughout the five phases of the AFA review initiated as part of legal proceedings. Our team monitors the process by which the AFA validates the company's framework policies.

Accolades

Navacelle once again in 2025 picked in

Corporate Compliance & Investigations

Sources say: "They have extensive experience in all kinds of criminal proceedings and large-scale internal investigations"

Stéphane de Navacelle once again in 2024 picked in

Compliance & Investigations

Sources say: "Stéphane de Navacelle's biggest strength is his ability to handle the technical legal aspects of corporate criminal investigations in France"

NAVACELLE recognized once again in 2024 in

WHITE COLLAR CRIME

Sources say: “A strong team which is able to deal with complex white-collar matters including those with a cross-border element.
The firm is very adaptable to changing circumstances and able to respond quickly to increases in workload requirements.
A very good sense of the overall strategy in any case.”