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French Corporate Environment Not So Whistleblower-Friendly

Client Alert | less than 1 min read | 01.09.06

It appears that the French government has a very different philosophy from that of the U.S. government when it comes to employee whistleblowers. As the attached article (http://www.crowell.com/pdf/Newsroom/ DataProtection_Dhont.pdf) discusses in depth, far from seeking to encourage and reward whistleblowing, French law is affirmatively concerned that the practice may abuse individuals' privacy and data-protection rights, with the result that in the past year, French regulators and courts have struck down Sarbanes-Oxley-inspired efforts by several American companies to implement ethics hotlines for their French employees, and the most recent French regulatory guidance permits such hotlines only under limited circumstances, and with appropriate safeguards to prevent defamation and protect privacy.

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Client Alert | 7 min read | 06.24.26

DOJ’s National Security Division Announces First Declination Under New Corporate Enforcement Policy With Parallel BIS Settlement

On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch....

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