Decoding AFA’s Guide on Sponsorship and Charitable Donations

This technical report discusses the French Anti-Corruption Agency's (AFA) guide on corporate sponsorship and charitable donations, published on March 26, 2024. The guide outlines the risks associated with these activities and provides compliance recommendations to mitigate corruption risks. It emphasizes the importance of implementing corporate compliance measures, including policies, written agreements, training, and internal controls. The report compares the AFA's recommendations with standards in the United States and the United Kingdom, highlighting the legal frameworks governing charitable contributions and sponsorships in these regions. In France, while not legally mandated, the establishment of clear policies is strongly recommended to avoid conflicts of interest and misuse of resources. The report also details the necessary elements of a comprehensive policy and the due diligence expected by US authorities under the Foreign Corrupt Practices Act. In the UK, the Bribery Act's requirements for adequate procedures to prevent bribery are also discussed, underscoring the need for companies to navigate these risks carefully.