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Loi Sapin II Compliance: Article 17 Requirements and AFA Audit Expectations
What Article 17 of Loi Sapin II requires, who it applies to, how AFA audits work, and a 120-day plan to structure your anti-corruption program.
Fines for Non-Compliance Start Before the Penalty
The fine is announced on a Tuesday, but the company started paying for it months earlier, when Legal sent the first preservation notice and Finance froze a payment batch. That is the part most board reports miss. The public penalty is clean. One press release.
Paper vs Real Compliance: What Auditors Actually Test
Auditors don't fail you for missing policies — they fail you for missing evidence. The 3 tests every compliance audit applies, and how to pass them.
Compliance Culture Breaks Down Where Incentives Do: A Compliance Officer's Guide
The sales director does not need to ask anyone to break the rules; the bonus plan already did. A company can say it values integrity, require annual training, publish a code of conduct, and still teach people something else every Monday morning. Hit the quarterly number.
Compliance Program or Culture? Why You Need Both
The most uncomfortable audit moment is not when a policy is missing. It is when every policy exists and nobody can explain what people actually do when pressure hits.