Welcome back to the podcast, bribes, Windler-Steel or Steel.

I'm Alexandra Addison, and today we're talking about the now 10-year-old

Sepon-Due law in France, and specifically its compulsory internal compliance program.

My guest is Dan Seltzer.

Until last month, Dan was managing director

at Accenture and senior director of anti-corruption and government compliance there.

He has recently joined Frost LLP as a partner in their Silicon Valley office. Dan has an

extraordinary depth of experience with complex compliance issues, and for our purposes today,

he guided Accenture through their

Sapon-Due compliance audit. Dan, thank you for joining me. Thank you, Alexander. Great to be here.

Can you start by just setting the scene for us? What are these audits? When did Accentures take place?

And how collaborative or perhaps adversarial was the whole process?

It's a really unique law, as you kind of alluded to at the outset, and that it is one of the few

anti-corruption laws in the world that actually has a compulsory compliance program requirement

for companies of a certain size or companies who have been

convicted of a corruption offense. More relevant to most of your listeners is companies with over

500 employees and a hundred million dollar annual or 100 million euro annual turnover are

required to adopt a anti-corruption compliance program. And it's not just that they're required to adopt any anti-corruption compliance program. And it's not just that they're required

to adopt any anti-corruption compliance program. It's a very prescriptive description of an

anti-corruption compliance program. And so I think for most of us who've been in this field for a while,

this is a unique dynamic. Usually countries like the U.S. and the U.K., even where

they've put out detailed guidance on what they think constitutes an effective compliance program,

...