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AO A&O Shearman More A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world.
The French Anti-Corruption Agency (the AFA) has shifted its approach: it now sanctions breaches identified at the time of its inspection, imposing financial penalties for the first time on both the regulated entity and its director. Delayed remedial action and compliance measures will no longer provide protection.
Introduction On July 9, 2026, the AFA’s Enforcement Committee (the Committee) handed down an unprecedented decision since the entry into force of the Sapin 2 Law of December 9, 2016 on transparency, the fight against corruption and the modernisation of economic life (known as “Sapin 2”).
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