How to Assess Risk Under Sapin II

In today’s increasingly complex anti-corruption enforcement environment, regulators are consistent in indicating that risk assessments are fundamental components of strong compliance programs but have different views on what those risk assessments should entail. In a guest article, Bryan Sillaman and Nicolas Tollet, Hughes Hubbard partners based in Paris, examine the different approaches taken by two important jurisdictions – the United States and France – and attempt to offer four practical suggestions for companies balancing increasingly challenging internal and external expectations when developing and implementing their anti-corruption compliance programs. See the Anti-Corruption Report’s three-part guide to risk assessments: “Types of Assessments” (Jun. 26, 2019); “Techniques and Building a Team” (Aug. 7, 2019); and “Where to Look for Risk and Risk Ranking” (Sep. 4, 2019).

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