Compliance

Compliance : financial crime and anti-corruption programs

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Reviewed by Nathalie Dreyfus, European trademark and patent attorney. Last updated : May 2026.

Table of contents

Why integrate compliance into your French and EU operations

France has built one of the most demanding financial crime and anti-corruption frameworks in Europe. The Sapin II Act of 2016 forces companies above defined thresholds to deploy formal anti-corruption programs supervised by the French anti-corruption agency  (AFA). AML/CTF rules transpose successive EU directives, with sanctions enforced by ACPR and TRACFIN.

For international groups, the cost of misalignment between EU, US (OFAC, FCPA), UK and other regimes can be massive. Our compliance practice helps you converge frameworks, deploy them operationally, and prepare for AFA, ACPR and counterpart audits.

Sapin II

French anti-corruption act since 2016

Sapin II requires companies above defined thresholds to deploy eight pillars of anti-corruption compliance, supervised by the AFA. Fines reach 1 million euros for legal entities.

Source: Loi n° 2016-1691 du 9 décembre 2016 (Sapin II).

AFA

French Anti-Corruption Agency

The French anti-corruption agency  audits companies subject to Sapin II and issues guidelines, sanctions and corrective measures. Several high-profile cases have been concluded since 2018.

Source: Agence française anticorruption, annual reports.

AMLD6

Sixth EU AML directive

The EU has progressively reinforced AML/CTF rules, culminating in AMLD6 and the new AML Authority (AMLA) due to open in 2025-2026 in Frankfurt.

Source: EU AML package and Regulation (EU) 2024/1620.

OFAC + EU sanctions

Cross-border sanctions complexity

Companies must navigate EU sanctions (against Russia, Belarus, Iran, North Korea and others), US OFAC sanctions and UK sanctions in parallel, with diverging scope and penalties.

Source: European Council sanctions map, OFAC SDN list 2025. 

Our compliance offer with Cogethos

Step 1

AML / CTF (anti-money laundering, counter-terrorism financing)

Implementation of Target Operating Models for alert processing, optimisation of AML/CTF tools, outsourced alert processing, audits, dedicated training.

Step 2

International sanctions and embargoes

System implementation, cross-border transaction filtering, sanctions list tuning, outsourced alert processing for transactions, existing customers and prospects, training.

Step 3

Know your customer (KYC)

Procedure design, customisation of risk rating systems (clients, intermediaries, suppliers), outsourced CDD and EDD file processing, audits, training.

Step 4

Anti-corruption (Sapin II, FCPA, UK Bribery Act)

Sapin II program deployment, AFA audit preparation, anti-corruption risk mapping, third-party due diligence, dedicated training.

Step 5

Risk mapping and financial security

Comprehensive risk mapping per theme, predefined financial security solutions for digital banks, integration into broader compliance and ESG programs.

Why IP businesses care about compliance

Beyond the financial crime focus, compliance increasingly intersects with intellectual property in three ways.

  • Customer due diligence on suspicious licensees, especially in luxury, wine and tech sectors where reputational risk is high.
  • Sanctions screening of distributors, agents and franchisees before granting trademark or patent licences.
  • Anti-bribery clauses in IP contracts, particularly for emerging markets exposures (China, Russia, Middle East, Africa).

Our combined IP and compliance expertise lets us deploy programs that protect both your IP value and your regulatory standing.

Our compliance services

  • AML / CTF programs

    Procedure design, alert processing, tool optimisation, training.

  • KYC programs

    Risk rating, CDD and EDD outsourcing, system audits.

  • Sanctions screening

    Cross-border transaction filtering, customer screening, list tuning.

  • Anti-corruption

    Sapin II, FCPA, UK Bribery Act programs and AFA audit preparation.

  • Risk mapping

    Tailored risk mapping per theme and per business unit.

  • Training and awareness

    Custom sessions for compliance, legal, sales and procurement teams.

Q&A on compliance

What is Sapin II and who does it apply to ?

Sapin II is the French anti-corruption act of 2016. It requires French companies above 500 employees and 100 million euros in turnover, and their international groups, to deploy eight pillars of anti-corruption compliance, with sanctions imposed by the AFA.

What is the difference between AML and KYC ?

Anti-money laundering (AML) is the broader framework to detect and prevent money laundering and terrorism financing. Know your customer (KYC) is one component of AML : the process of identifying and verifying clients and beneficial owners. KYC feeds AML risk analysis.

Do EU sanctions apply to my non-EU company ?

EU sanctions apply to EU persons, EU companies, business done in the EU and EU-related transactions (denominated in euros, routed through EU banks, involving EU goods). Non-EU companies must implement screening to avoid breaching extraterritorial scope.

What is the new EU AML Authority (AMLA) ?

AMLA is the new EU AML Authority, opening in Frankfurt in 2025-2026. It will directly supervise high-risk financial institutions and coordinate national supervisors. Its role significantly raises the EU AML enforcement bar.

How is Sapin II compliance audited ?

By the AFA, which can conduct on-site or off-site audits. The agency assesses the eight pillars : tone from the top, risk mapping, third-party due diligence, internal controls, accounting controls, training, whistleblowing, sanctions regime. Non-compliance triggers corrective injunctions and fines.

Can compliance programs be outsourced ?

Yes, partially. Many AML/CTF and KYC processes can be outsourced under regulator-supervised conditions. Strategic responsibilities (designated officer, Sapin II program governance) remain inside the company. Cogethos and Dreyfus combine outsourced delivery with internal capacity building.

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