Welcome back to the podcast, bribed, swindle, or steel. I'm Alexandra Ragi, and today we're

continuing our series on the OECB Anti-Bribery Convention, how specific countries have performed to date,

and we're looking ahead to action on the new recommendation that came out in November.

Today we're talking about France specifically, and my guest is Jan Dunan Vosovic.

Jan is counsel with Hughes Hubbard and Reid, where he focuses his practice on cross-border

compliance and regulatory enforcement. He also focuses on multi-jurisdictional internal and

government investigations, transnational litigation, and international arbitration.

Having trained in both the common law and civil law systems, Jan is well placed to talk us through some of those distinctions.

He's also the co-editor of an excellent book that came out last year. We've discussed it on this podcast previously, The Transnationalization of Anti-Corruption Law.

Jan, thank you so much for joining me.

Hello, and thank you so much for having me on the program.

Can you just jump in and provide a bit of background on France's accession to the OECD Convention?

Just a brief overview of the history before we launch into how they

have fared since. France ratified the OECD anti-bribery convention on July 31st, 2000. So it's been over 20

years now, and the Working Group has published, I think, six reports concerning France.

Without going into a great deal of detail, because, as you say, over 20 years, there has been a lot of back and forth.

How is France fared generally in the peer review process?

The Phase 4 report on France was published in December of 2021.

And I think to understand the significance of this report, it's important to take a step back.

As I mentioned, there's been six reports, 2004, 2006, 2012, 2014, leading up to 2021.

I believe the turning point in France's experience and performance in the

working group was the 2012 Phase 3 report. And this was a very important report because then

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