Welcome back to the podcast, Bride, Swindle, or Steel.

I'm Alexandra Rogge and today we're in Paris.

My guest today is Dominique Mondaloni.

Dominique is with Wilkie Farr in Paris.

He handles commercial litigation, arbitration, and for our purposes,

white-collar criminal investigations. He regularly counsels clients on the OECD Convention on Combating

Bribary and the U.S. Foreign Corrupt Practices Act. Today we're going to talk about the anti-bribery

enforcement record here in France and the newly enacted Sapan Dre. Dominique, thank you for joining me.

You're very welcome and thank you for having me.

Let's start with the French anti-bribery law prior to Sampant-Dur.

Can you describe the scope and perhaps compare it to the FCPA or the UK Bribery Act with

which most people are more familiar?

The French statute on anti-bribery dates back to 2000. That's the year in which we enacted

the OECD Convention of 1997. The definition of the offense in 2000 resembled very closely the one

in the FCPA. The fines, however, or the sanctions for misbehavior were not extremely high.

And over the years, the legislature has it reinforced our statute and our criminal sanction of

foreign corrupt practices. But all in all, I'd say that as a legal matter, France has, since 2000,

have had an arsenal which would have been sufficient to enforce.

The problem has never been really the law itself, but the criminal procedure and the willingness to enforce it.

It's been a question of culture and a question of procedure or criminal procedure.

But as far as the statute itself is concerned, I think we've had the instruments in the arsenal in place.

We've reinforced it because the OECD has been critical or has often criticized our criminal

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