In a corporation with a board of directors, the chairman of the board and the chief executive officer bear personal responsibility. This responsibility is accompanied by penalties of up to 200,000 euros for natural persons.

The loi Waserman of 21 March 2022 broadens the definition of whistleblowers to include not only current or former employees, but also trainees, job applicants, external collaborators, shareholders, members of governing bodies, and contracting parties.

The Parquet national financier, headed by prosecutor Jean-François Bohnert, is the judicial authority with jurisdiction for prosecutions relating to transnational corruption, influence peddling, and aggravated tax fraud.

The AFA's functions include advising, inspecting, coordinating, and monitoring CJIPs. During inspections, it systematically requests to meet a board member to assess the involvement of governance bodies.

According to the text, the criteria include a workforce of at least 500 employees (calculated in accordance with French Labour Code rules, including fixed-term and temporary contracts on a pro-rata basis) and annual or consolidated turnover exceeding 100 million euros. Approximately 1,600 companies directly meet these criteria in France.

The text specifies that the appointment of a compliance officer is not legally mandatory, but the AFA strongly recommends such an appointment, formalised by a letter of engagement from senior management.

Sanctions for natural persons can reach 200,000 euros. Entities may be subject to financial sanctions or administrative measures. Whistleblowers benefit from enhanced protection since the loi Waserman.

The compliance officer's responsibilities include framework management, coordination of legal, procurement, HR, finance, and audit functions, development and updating of the risk map, training and awareness-raising, alert management, third-party assessment, and periodic reporting to management.