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Olympic compliance and Paris 2024: It’s France’s turn to lead

The Paris 2024 Summer Olympics present an historic opportunity for the Olympic Movement, the French compliance industry, and the global anti-corruption effort. In a brief two-year span -- 2016 to 2017 -- three extraordinary events converged:

• The International Olympic Committee formalized a new policy of contractually obligating host cities and their Olympic organizations to adopt anti-corruption and human rights compliance;

• At the same time, France was enacting its landmark anti-corruption compliance law, Sapin II, and a corporate human rights obligation, the Duty of Vigilance Law, heralding a new era for France’s compliance industry; and

 • The IOC selected Paris to host the 2024 Games, inviting France to set the standard for Olympic corruption and human rights compliance.

Because these next six years are critical, the French compliance association, Le Cercle de la Compliance, launched Compliance 2024 earlier this month. Compliance 2024 is a working group of French compliance professionals (in-house and outside counsels and service providers) who will join forces and perspectives to offer a detailed framework for the components and the monitoring of the Paris 2024 Compliance program.

Le Cercle de la Compliance asked Prof. Andy Spalding, who has spent years studying anti-corruption movements in the Olympic host countries of Brazil and South Korea, to assemble the Olympics Compliance Task Force. The Task Force’s mission is to research international law and best practices on anti-corruption and human rights compliance generally and mega sporting events in particular.

Working together, the Task Force and Compliance 2024 will help turn international laws, standards, and aspirations into actual practice.

They will build a three-tier framework:

 1. International corruption and human rights laws and standards generally;

 2. The specific corruption and human rights risks associated with the Olympic Games;

 3. How both will apply in practice to France’s unique legal, economic, and cultural context.

This is a new initiative, addressing a new form of Olympic corruption. For decades the world has wrestled with doping, match-fixing, and bidding scandals; we’ve adopted a number of reforms and now see them taking effect. But host city corruption -- the risks that arise in the host country after the Games are awarded, in the seven years leading up to the event -- is a distinct form of corruption requiring distinct anti-corruption measures. Just what are the corruption and human rights risks associated with the Paris 2024 Summer Games?

What does the framework of applicable national and international laws and standards look like? And which specific compliance measures are needed to mitigate these risks? The partnership of Compliance 2024 and the Olympics Compliance Task Force will provide rigorous, well-researched answers to these and other questions.

We believe that despite the well-known corruption and human rights challenges, the Olympic Games can actually be a catalyst for host-country governance reform. We believe the Olympics can leave what we’re calling a Governance Legacy -- a series of new laws, practices, and norms promoting transparency and accountability, that have application beyond sport, and that will endure after the Games are gone.

In future posts, we’ll provide further detail on the IOC’s new corruption and human rights requirements, the relevant national and international laws, and the first steps in designing a compliance framework. Watch this space . . . now and through 2024.


Cecilia Fellouse-Guenkel, pictured above left, is the Secretary General of Le Cercle de la Compliance and in charge of Compliance 2024. Le Cercle de la Compliance’s mission is to organize the French compliance community in all its diversity around a pragmatic, actionable and innovative approach of compliance.

Andy Spalding, above right, chairs the Olympic Compliance Task Force. He is Professor at the University of Richmond School of Law (Virginia, USA), a Frequent Visiting Instructor at the International Anti-Corruption Academy in Austria, and Senior Editor of the FCPA Blog.