Read and listen to Jody Wilson-Raybould`s latest SNC-Lavalin evidence, CBC News (March 29, 2019) www.cbc.ca/news/politics/wilson-raybould-committee-documents-audio-1.5077533. On 26 June 2019, the French National Financial Prosecutor (PRF) and the French Anti-Corruption Authority (“AFA”) issued guidelines (the “PRF-AFA guidelines”) regarding the comparison mechanism for companies in France, known as the Judicial Public Interest Agreement (CJIP). The French law on transparency, the fight against corruption and the modernization of economic life (“Sapin II””) created the CJIP procedure which gives prosecutors the power to allow a company suspected of committing a concealed crime to close the case without formal prosecution.  Prosecutors may offer a CJIP to a company suspected of having committed acts of corruption, corruption, tax evasion or money laundering stemming from tax evasion.  The implementation of Sapin II and the first CJIPs completed under the Act were discussed in our 2016 and 2017 and 2018 year-end updates. The agreement allows for the suspension of proceedings for a specified period of time, provided that the organization meets certain conditions. This year, the DOJ closed seven NPAs and data protection authorities regarding allegations of violations of the Foreign Corrupt Practices Act (“FCPA”). These agreements included the third most important resolution in 2019, a Dpa with Swedish telecommunications company Ericsson, which imposed a total of nearly $1.1 billion in monetary bonds. Together, the seven FCPA resolutions imposed a total of approximately $2.8 billion, or about 36% of the total monetary recovery this year. Only one of the FCPA`s decisions included voluntary self-certification by the colonization company, and four of the seven agreements established independent compliance monitors. A more detailed analysis of this year`s FCPA decisions can be provided in our FCPA 2019 end-of-year update.