The Sanctions Committee of the Agence Française Anticorruption (AFA) has issued a decision marking a decisive inflection point for companies in the enforcement of the French anti-corruption framework. For the first time since its establishment, the Sanctions Committee imposed direct financial penalties on a company and its chairman for failing to comply with their obligations regarding the implementation of an anti-corruption compliance program. In this guest article, Proskauer partner Bryan Sillaman and associate Mélinée Aprikian discuss how this decision underscores that compliance requirements cannot be approached as a mere tick-the-box exercise and how it appears to signal a departure from the gradual, remediation-focused approach that characterized the AFA’s early enforcement decisions, with the emphasis now shifting toward effective implementation of a compliance program at the time of the audit. For more from Proskauer, see “The Changing Landscape of the French ‘Secret Professionnel’” (Apr. 8, 2026).