Compliance, Internal Investigations, International Sanctions and Criminal Risk Management
Me de Foucher advises corporate clients on the establishment, organisation or audit of compliance systems in line with the international and domestic legal framework applicable to them (duty of vigilance, Sapin II requirements, AML/CFT mechanisms, internal controls, internal whistleblowing systems, etc.).
He also advises on risk management relating to compliance with international sanctions regimes.
He further supports clients in managing internal investigations (organising and conducting them on behalf of corporate clients, or assisting and representing individuals in connection with an internal investigation conducted by a corporate entity).
Lastly, Me de Foucher frequently counsels legal entities (companies, associations, public bodies, etc.) and their executives on managing criminal risk within their organisation, in particular through the implementation of delegation-of-authority systems.
Representative matters handled by the firm:
- Acting as compliance expert in proceedings conducted by the World Bank under its independent accountability mechanism
- Crisis management within a listed group concerning a product quality defect liable to cause serious mechanical failures in the aeronautics sector
- Structuring and advisory mission for the development of a risk map in the banking sector
- Drafting codes of conduct and ethics charters for a group operating in the energy sector
- Structuring a dedicated internal investigations function and drafting a practical guide to investigation and whistleblowing procedures (Sapin II) for another energy-sector group
- Conducting an internal investigation into potential breaches of probity and violations of the company’s code of conduct within an insurance group (supervising the team and various resources — forensic operations)
- Leading an internal inquiry into suspected public and private corruption
- Designing a delegation-of-authority system within a private group for the management of corporate criminal risk – Assisting an individual in connection with an internal investigation conducted within his company into practices in which he had taken part.
