The Judicialization of Global Economic Life

Since the Alstom case, European executives know that the American Department of Justice (DOJ) can sanction corruption practices with no direct link to US soil, simply through the use of the dollar. This is extraterritoriality. Facing this threat, compliance is not an administrative burden: it is a sovereign shield.

The Sapin II Law as a Bulwark

Often perceived as a constraint, the Sapin II Law is actually our best defense. By imposing compliance standards on French companies as high as Anglo-Saxon standards, it allows the French justice system to take up cases before foreign authorities do.

Internal Audit: Crisis Methodology

When a suspicion emerges, the reaction must be immediate. Here is the methodology we recommend in judicial crisis management:

PHASE 1: INFORMATION FREEZE
- Securing servers and emails.
- Suspension of document destruction (Legal Hold).

PHASE 2: INTERNAL INVESTIGATION
- Mapping of third parties (suppliers, intermediaries).
- Forensic financial audits.
- Confidential interviews.

PHASE 3: REMEDIATION
- Self-disclosure (Judicial Convention of Public Interest - CJIP).
- Updating the compliance plan

The Importance of the "Trusted Third Party"

Conducting these investigations internally is risky (conflict of interest, lack of perspective). Recourse to an external firm guarantees the necessary impartiality before regulators. In a world where reputation takes years to build and a minute to collapse, probity is the company's new tangible asset.