ReinhartMarvilleTorre

Compliance

The firm’s Compliance team is led by two specialists in white-collar crime and commercial litigation.

Marion Lambert-Barret and Fanny Rocaboy are offering a very pragmatic and operational approach to the compliance legal issues that are currently facing French and International companies.

The team is assisting clients (multinational or French companies and individuals) in every phase of corporate compliance and regulatory enforcement:

  • Upstream, to implement the compliance policy programs in order to meet the regulations’ requirements (anti-bribery and corruption policy, whistleblowing system, money laundering, terrorist financing, risk mapping and monitoring plans, etc.).
  • Downstream, to provide assistance during the control and investigation of regulatory authorities (French Anti-Corruption Agency, World Bank investigation, Customs, DGCCRF…)
  • in the event of negotiation with the public prosecutor’s office (Public Interest Agreement), as part of a preliminary investigation or judicial investigation.

Compliance with the Sapin II Law:

  • Design and implementation of compliance policy programs (in France and in foreign subsidiaries)
  • Risk mapping
  • Third-party due diligence procedures
  • Assistance in the event of an audit of the FAA and before the FAA’s Enforcement Committee
  • Internal investigation and due diligence (in order to implement or to enhance compliance policy programs, mergers and acquisitions)
  • Assessment of the exposure of directors’ criminal liability
  • Preventive training about FAA controls
Compliance AML – TF:

  • Design and deployment of specific systems and process to identify and assess the risks of money laundering and terrorist financing
  • Risk mapping
  • Implementation of Know-Your-Clients/Customers procedures (KYC)
  • Assistance in case of control (Customs, DGCCRF) and defense before the National Sanctions Commission (CNS)
  • Drafting of suspicious transaction reports
  • Compliance audits and training of employees and managers

Vigilance Plan

  • Risk mapping
  • Implementation of procedures’ implementation to evaluate the situation of subsidiaries, subcontractors and/or suppliers,
  • Training and audit of the existing system
  • Setting up the alert system
  • Crisis assistance and communication management