Ryan Rohlfsen Interviews The Head of The French National Financial Prosecutor’s Office Regarding Cross-Border Enforcement at the ACI FCPA & Anticorruption for Life Sciences Industry Conference

This morning at the ACI FCPA & Anti-Corruption for the Life Sciences Industry conference in New York, Ryan Rohlfsen, a partner and co-head of the global anti-corruption and international risk practice at Ropes & Gray, interviewed Jean-Francois Bohnert, the head of the Parquet National Financier (the “PNF”), France’s enforcement agency prosecuting corruption and tax fraud. The discussion focused on the increasing anti-corruption enforcement in Europe and recent formation of the International Anti-Corruption Prosecutorial Taskforce (the “Taskforce”).

The Taskforce was formed by the British, French, and Swiss law enforcement authorities in late March 2025. While the PNF has worked closely with the British and Swiss prosecutors for years, the Taskforce seeks to create an open line for regular communications and boost cooperation across the borders. The Taskforce charter envisioned that other ”like-minded agencies” might join in the future.  Just a month later, Mr. Bohnert said, the Taskforce has already received inquiries and expressions of interest in cooperation from enforcement agencies in Germany, Netherlands, Italy, Spain and several Latin American jurisdictions. There are no signs of any slowdown in anti-corruption enforcement in Europe.

Key takeaways from the conversations included:

1. Broad focus of anti-corruption enforcement in Europe: Mr. Bohnert spoke about Taskforce as a mechanism to increase cross-border cooperation and noted that regulators are not focusing on any particular industry or geography; instead they are seeking to investigate a broad array of misconduct.
2. Strong compliance programs matter: Under French law, companies are legally bound to establish and maintain robust compliance programs. This requirement is not limited to French companies. The expectation is the same for multinationals operating in France and falling under the PNF’s jurisdiction.
3. Self-reporting and proactive cooperation are strongly encouraged by governmental authorities: A few weeks ago, the Serious Fraud Office in the UK (the “SFO”) issued a new guidance on self-reporting and expectations around cooperation for corporations. The SFO signaled benefits of early disclosure: companies that self-report and fully cooperate, will be invited to enter into DPA negotiations. While there is no legal obligation to self-disclose potential misconduct in France, Mr. Bohnert talked about importance of proactively engaging in communications with the PNF: “come knock at our doors before we knock at yours.” Transparency and cooperation are viewed favorably and will be beneficial for the company.