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💬Les juges vont être de plus en plus présents dans le droit de la compliance

🌐follow Marie-Anne Frison-Roche on LinkedIn 🌐subscribe to the Newsletter MAFR Regulation, Compliance, Law  - ► Full reference: M.-A. Frison-Roche, , F. Ancel, N. Roret, "Les juges vont être de plus en plus présents dans le droit de la compliance" ("Judges will be more and more involved in Compliance Law"), interview with Olivia Dufour, Actu-Juridique, 1st March 2023. - 💬read the interview (in French) - ► Presentation of the interview by the journal (in French) : "À l’instigation du professeur Marie-Anne Frison-Roche, l’École nationale de la magistrature (ENM) a proposé pour la première fois début février une formation en compliance à destination des magistrats et des avocats. François Ancel, conseiller la Cour de cassation, Nathalie Roret, avocate et directrice de l’ENM et Marie-Anne Frison-Roche plaident d’une seule voix pour le renforcement du rôle des acteurs judiciaires dans la compliance." - ► Questions asked (in French):  D’où est venue l’idée d’aborder ce droit en cours d’émergence qui semble encore très confidentiel ? En effet, on croit souvent savoir ce qu’est la compliance, en la confondant avec la conformité, pouvez-vous expliquer ce qui les distingue ?​​ On constate, en lisant le programme de la formation, que toutes les branches du droit sont concernées par la compliance depuis le droit des sociétés jusqu’au pénal en passant par les contrats et la responsabilité. Pouvez-vous nous donner des exemples ?​ Comment se redistribuent les rôles entre les avocats, les juges et les entreprises dans cette nouvelle configuration qu’est la compliance ?​ En quoi est-ce important pour les magistrats d’appréhender ce nouvel univers ?​ Ces transformations sont-elles cantonnées à la compliance ou peuvent-elles sortir de son champ ?​ Par exemple qu’en est-il de la question très controversée du rôle de l’avocat à l’égard du juge ?​ Avez-vous constaté lors de cette formation une amélioration du dialogue entre les différents acteurs ?​ Cette formation va-t-elle être instituée de manière permanente dans la formation des magistrats et des avocats ? Une autre manifestation est-elle prévue ? -

Publication director

🏗️ copublishing and direction of the collection: 📚Régulations & Compliance

Publication of🕴️M.-A. Frison-Roche (ed.), 📕 La juridictionnalisation de la Compliance

► Full Reference: M.-A. Frison-Roche (ed.), La juridictionnalisation de la Compliance, série “Régulations & Compliance“, Journal of Regulation & Compliance (JoRC) and Dalloz, 2023, 490 p.  - ► This book in few words: Sanctions, controls, appeals, deals: judges and lawyers are everywhere in the Compliance mechanisms, creating unprecedented situations, sometimes without a solution yet available.  Even though Compliance was designed to avoid the judge and produce security by avoiding conflict. This jurisdictionalisation is therefore new. Forcing companies to prosecute and judge, a constrained role, perhaps against their nature. Leading to the adaptation of major procedural principles, with difficulty. Confronting arbitration with new perspectives. Putting the judge at heart, in mechanisms designed so that he is not there. How in practice to organize these opposites and anticipate the solutions? This is the challenge taken up by this book. - 📘 In parallel, the English version of this book, Compliance Jurisdictionalisation, is published in the series co-published by the Journal of Regulation & Compliance (JoRC) and Bruylant.  - 📅  This book comes after a  cycle of colloquia organised in 2021 by the Journal of Regulation & Compliance (JoRC) and its Academic Partners. -   This volume is the continuation of the books dedicated to Compliance in this collection. ► Read the presentations of the other books in the series: the following books: 🕴️M.-A. Frison-Roche and M. Boissavy (eds.), 📕Compliance et droits de la défense. Enquête interne – CJIP – CRPC, 2024 🕴️M.-A. Frison-Roche (ed.), 📕L’Obligation de Compliance, 2025 🕴️M.-A. Frison-Roche (ed.), 📕Compliance et Contrat, forthcoming 🕴️L. Laref (ed.), 📕Compliance et vigilance bancaire, forthcoming 🕴️M.-A. Frison-Roche, 📕Le système juridique de l’adressage de l’Internet. Une structure multi-acteurs, gage de durabilité (The Legal System of Internet Addressing. A Multi-Stakeholder Structure, the Pledge of its Sustainability), forthcoming 🕴️M.-A. Frison-Roche (ed.), 📕Le système probatoire de la Compliance, forthcoming   the previous books: 🕴️M.-A. Frison-Roche (ed.), 📕Les Buts Monumentaux de la Compliance, 2022 🕴️M.-A. Frison-Roche (ed.), 📕Les outils de la Compliance, 2021 🕴️M.-A. Frison-Roche (ed.), 📕Pour une Europe de la Compliance, 2019 🕴️N. Borga, J.-Cl. Marin and J.-Ch. Roda (eds.), 📕Compliance : l’entreprise, le régulateur et le juge, 2018 🕴️M.-A. Frison-Roche (ed.), 📕Régulation, Supervision, Compliance, 2017 🕴️M.-A. Frison-Roche (ed.), 📕Internet, espace d’interrégulation, 2016 📕 Read the presentations of the other titles of the collection. - ► General presentation of the book: There have always been Judges and Lawyers in Compliance Law, because this branch of Law is an extension of Regulatory Law in which they have a core place. This results from the fact that the decisions taken in respect of Compliance are contestable in Court, including Arbitration, those issued by the Company, such as those of States or Authorities, the Judge in turn becoming what Compliance Law is effective. The novelty lies more in the phenomenon of “jurisdictionalisation”, that is the trial model penetrates all Compliance Law, and not only the Ex-Post part that it includes. Moreover, it seems that this jurisdictionalisation influences the non-legal dimension of Compliance. This movement has effects that must be measured and causes that must be understood. Advantages and disadvantages that must be balanced. If only to form an opinion vis-à-vis Companies that have become Prosecutors and Judges of themselves and others …: encourage this “Jurisdictionalisation of Compliance”, fight it, perhaps influence it? In any case, understand it! - 🏗️ General construction of this book: The book begins by a double Introduction, the first (in free access) summarizing the book, the second, substantial, relating to the need to reinforce the Judge and the Lawyer to impose the Compliance Law as a characteristic of the Rule of Law.  The first Part is devoted to what is specific to Compliance Law. of Compliance: the transformation of companies into Prosecutors and Judges of themselves, even of others. The second Part relates to Compliance general procedural Law, the procedure being the way between the dispute and the judgement.  The third Part continues this journey to the judge and aims to measure the influence of the reasoning and requirements of Compliance Law in dispute resolution methods where it was not, with some exceptions, present, but where it has a great future: Arbitration. Because trial and judicial decision are inseparable, because legal techniques and the Rule of Law should not be divided but compliance techniques could paradoxically be the weapon of their dissociation, because the power to judge and the procedures surrounding the latter must not be dissociated, because therefore Compliance mechanisms and the Rule of Law must be thought out and practiced then, the rise in power of one must be the sign of the rise in power of the other, and not the price of the ‘weakening of the Rule of Law, the fourth Part relates to the Judges in the Compliance mechanisms and culture.  -   DOUBLE INTRODUCTION 🕴️M.-A. Frison-Roche, 📝Lignes de force de l’ouvrage La juridictionnalisation de la Compliance free access to the full text  🕴️M.-A. Frison-Roche, 📝Conforter le rôle du Juge et de l’Avocat pour imposer la Compliance comme caractéristique de l’État de Droit   I. L’ENTREPRISE INSTITUÉE PROCUREUR ET JUGE D’ELLE-MEME ET D’AUTRUI PAR LE DROIT DE LA COMPLIANCE (“THE COMPANY ESTABLISHED PROSECUTOR AND JUDGE OF ITSELF AND OTHERS BY COMPLIANCE LAW”) 🕴️M.-A. Frison-Roche,📝 Le “jugeant-jugé”. Articuler les mots et les choses face à l’éprouvant conflit d’intérêts  🕴️C. Granier, 📝Réflexions sur l’existence d’une jurisprudence des entreprises 🕴️L.-M. Augagneur, 📝La juridictionnalisation de la réputation par les plateformes 🕴️A. Bruneau, 📝L’entreprise juge d’elle-même : la fonction compliance dans la banque 🕴️J.-M. Coulon, 📝Le Droit de la Compliance dans le secteur d’activité de la construction et les contradictions, impossibilités et impasses auxquelles les entreprises sont confrontées 🕴️Lapp, Ch., 📝La compliance dans l’entreprise : les statuts du process 🕴️J. Heymann, 📝La nature juridique de la “Cour suprême” de Facebook 🕴️D. Latour, 📝Les enquêtes internes au sein des entreprises 🕴️A. Bavitot,  📝Le façonnage de l’entreprise par les accords de justice pénale négociée 🕴️S. Merabet, 📝La vigilance, être juge et ne pas juger   II. LE DROIT PROCESSUEL À L’OEUVRE DANS LE DROIT DE LA COMPLIANCE  (“GENERAL PROCEDURAL LAW IN COMPLIANCE LAW”) 🕴️N. Cayrol, 📝Des principes processuels en Droit de la Compliance 🕴️F. Ancel,📝Le principe processuel de compliance, un nouveau principe directeur du procès ? 🕴️B. Sillaman, 📝Secret professionnel et coopération : les leçons de procédure tirées de l’expérience américaine pour une application universelle 🕴️A. Linden, 📝Motivation et publicité des décisions de la formation restreinte de la Commission nationale de l’informatique et des libertés (CNIL) dans une perspective de compliance 🕴️S. Scemla,🕴️D. Paillot, 📝La difficile appréhension des droits de la défense par les autorités de contrôle en matière de compliance 🕴️M.-A. Frison-Roche, 📝Ajuster par la nature des choses du Droit processuel au Droit de la Compliance   III. L’ARTICULATION DE LA COMPLIANCE ET DE L’ARBITRAGE INTERNATIONAL (“ARTICULATION BETWEEN COMPLIANCE LAW AND INTERNATIONAL ARBITRATION”) 🕴️J.-B. Racine, 📝Compliance et Arbitrage. Essai de problématisation 🕴️E. Silva-Romero,🕴️R. Legru, 📝Quelle place pour la Compliance dans l’arbitrage d’investissement ? 🕴️C. Kessedjian, 📝L’arbitrage au service de la lutte contre la violation des droits de la personne humaine par les entreprises  🕴️M. Audit, 📝La position de l’arbitre en matière de compliance 🕴️J. Jourdan-Marques, 📝L’arbitre, juge ex ante de la compliance ? 🕴️E. Kleiman, 📝Les objectifs de la compliance confrontés aux acteurs de l’arbitrage 🕴️F.-X. Train, 📝Arbitrage et procédure parallèles exercées au titre de la compliance 🕴️Cl. Debourg, 📝La compliance au stade du contrôle des sentences arbitrales   IV. LE JUGE DANS LE DROIT DE LA COMPLIANCE (“THE JUDGE IN COMPLIANCE LAW”) 🕴️M.-A. Frison-Roche, 📝Le juge, l’obligation de compliance et l’entreprise. Le système probatoire de la Compliance 🕴️J. Morel-Maroger, 📝La réception des normes de la compliance par les juges de l’Union européenne 🕴️S. Schiller, 📝Un juge unique en cas de manquement international à des obligations de compliance ? 🕴️O. Douvreleur, 📝Compliance et juge du droit 🕴️F. Raynaud, 📝Le juge administratif et la compliance 🕴️E. Wennerström, 📝Quelques réflexions sur la Compliance et la Cour européenne des droits de l’Homme - 🌐follow Marie-Anne Frison-Roche on LinkedIn 🌐follow Marie-Anne Frison-Roche on Instagram 🌐subscribe to the Newsletter MAFR Regulation, Compliance, Law 🌐subscribe to the Video Newsletter MAFR Surplomb

Articles in The Journal of Regulation & Compliance « JoRC »

📝Conforter le rôle du juge et de l’avocat pour imposer la Compliance comme caractéristique de l’État de Droit, in🕴️M.-A. Frison-Roche (ed.), 📕La juridictionnalisation de la Compliance

🌐 follow Marie-Anne Frison-Roche on LinkedIn 🌐 subscribe to the Newsletter MAFR Regulation, Compliance, Law  - ► Full Reference: M.-A. Frison-Roche, "Conforter le rôle du Juge et de l'Avocat pour imposer la Compliance comme caractéristique de l'État de Droit" ("Reinforce the Judge and the Attorney to impose Compliance Law as a characteristic of the Rule of Law"), in M.-A. Frison-Roche (dir.), La juridictionnalisation de la Compliance, coll. "Régulations & Compliance", Journal of Regulation & Compliance (JoRC) and Dalloz, 2023, pp. 29-55.  - ► This article is the introduction of the book.   - 📝read the article (in French)   - 🚧read the bilingual Working Paper which is the basis of this article, with additional developments, technical references and hyperlinks  -   📕read a general presentation of the book, La juridictionnalisation de la Compliance, in which this article is published - ► Summary of the article (done by the Journal of Regulation & Compliance): One can understand that the compliance mechanisms are presented with hostility because they seem designed to keep the judge away, whereas there is no Rule of Law without a judge. Solid arguments present compliance techniques as converging towards the uselessness of the judge (I). Certainly, we come across magistrates, and of all kinds, and powerful ones, but that would be a sign of imperfection: its ex-ante logic has been deployed in all its effectiveness, the judge would no longer be required… And the lawyer would disappear so with him… This perspective of a world without a judge, without a lawyer and ultimately without Law, where algorithms could organize through multiple processes in Ex Ante the obedience of everyone, the "conformity" of all our behaviors with all the regulatory mass that is applicable to us, supposes that this new branch of Law would be defined as the concentration of processes which gives full effectiveness to all the rules, regardless of their content. But supposing that this engineer's dream is even achievable, it is not possible in a democratic and free world to do without judges and lawyers. Therefore, it is imperative to recognize their contributions to Compliance Law, related and invaluable contributions (II). First of all, because a pure Ex Ante never existed and even in the time of the Chinese legists, people were still needed to interpret the regulations because a legal order must always be interpreted Ex Post by who must in any case answer the questions posed by the subjects of law, as soon as the political system admits to attributing to them the right to make claims before the Judge. Secondly the Attorney, whose office, although articulated with the Judge's office, is distinct from the latter, both more restricted and broader since he must appear in all cases where the judicial figure puts himself in square, outside the courts. However, Compliance Law has multiplied this since not only, extending Regulatory Law, it entrusts numerous powers to the administrative authorities, but it also transforms companies into judges, in respect of which the attorneys must deal with. Even more so, Compliance Law only takes its sense from its Monumental Goals. It is in this that this branch of the Law preserves the freedom of human beings, in the digital space where the techniques of compliance protect them from the power of companies by the way that the Compliance Law forces these companies to use their power to protect people. However, firstly, it is the Judges who, in their diversity, impose as a reference the protection of human beings, either as a limit to the power of compliance tools or as their very purpose. Secondly, the Attorney, again distinguishing himself from the Judge, if necessary, reminds us that all the parties whose interests are involved must be taken into consideration. In an ever more flexible, soft, and dialogical Law, everyone presenting himself as the "advocate" of such and such a monumental goal: the Attorney is legitimate to be the first to occupy this place. -

Articles in The Journal of Regulation & Compliance « JoRC »

WENNERSTRÖM, Erik🕴️

📝Quelques réflexions sur la Compliance et la Cour européenne des droits de l’homme, in 🕴️M.-A. Frison-Roche (ed.), 📕La juridictionnalisation de la Compliance

► Full Reference: E. Wennerström, "Quelques réflexions sur la Compliance et la Cour européenne des droits de l'homme" ("Some Reflections on Compliance and the European Court of Human Rights"), in M.-A. Frison-Roche (ed.), La juridictionnalisation de la Compliance, coll. "Régulations & Compliance", Journal of Regulation & Compliance (JoRC) and Dalloz, 2023, pp. 479-489. - 📕read a general presentation of the book, La juridictionnalisation de la Compliance, in which this article is published - ► Summary of the article (done by the Journal of Regulation & Compliance): The development of the European Court of Human Rights case law, contributing to European integration, has incorporated the substantial concept of ​​"compliance" which goes beyond the idea of ​​legality with respect to which companies remain passive, and promotes legal orders as systems in interaction with another.  The author develops the spirit and scope of Protocol 15 by which both the principle of subsidiarity and the margins of appreciation the signatory States are organized, mechanisms governed by the principle of proportionality. Subsidiarity means that the States are in the best position to design the most adequate application of the Convention, the close links between the States allowing its effective application. In addition, the new opinion procedure which allows a national court to have during a case the non-binding opinion of the ECHR ensures better compliance with the objectives of the Convention. The case-law of the Court takes up this substantial requirement through its doctrine, in particular identified in the Bosphorus case, by stressing that the accession of a State to the European Union presumes its compliance when implementing EU law with the obligations arising from the ECHR, even if this presumption can be refuted if the protection is manifestly lacking, which was admitted in several cases, in particular concerning the right to an impartial tribunal in matters of economic regulation. The different legal orders are thus articulated.  The author concludes that the European Court of Human Rights, like the Court of Justice of the Union, contributes to the construction of Compliance Law in Europe, from an Ex Ante perspective favoring opinions rather than Ex Post sanctions and creating, in particular through the Bosphorus doctrine, elements of security and confidence for European integration around common values. -

Articles in a legal collective publication

MOREL-MAROGER, Juliette🕴️

📝La réception des normes de la compliance par les juges de l’Union européenne, in 🕴️M.-A. Frison-Roche (ed.), 📕La juridictionnalisation de la Compliance

► Full Reference: J. Morel-Maroger, "La réception des normes de la compliance par les juges de l'Union européenne" ("Application of compliance standards by EU judges"), in M.-A. Frison-Roche (ed.), La juridictionnalisation de la Compliance, coll. "Régulations & Compliance", Journal of Regulation & Compliance (JoRC) and Dalloz, 2023, pp. 443-452.  - 📕read a general presentation of the book, La juridictionnalisation de la Compliance, in which this article is published - ► Summary of the article (done by the author): Compliance rules are intended to pursue objectives of public interest – or monumental goals – and thereby in principle modify and guide the behaviour of economic operators. In order to achieve these objectives, the full spectrum of norms are used in compliance matters. What is and what should be the role of the judges of the European Union in the development of compliance rules ? As in domestic law, the legality of compliance standards developed by regulatory authorities has been challenged. It will first be necessary to analyse what control the judges of the European Union have over these rules. The question arises essentially as regards the rules of soft law, the challenge of which can be considered in two ways : by way of an action for annulment and by exception by way of a preliminary ruling. But beyond the control of the legality of compliance rules exercised by European judges, they also contribute to their application. The effectiveness of compliance rules depend above all on them being followed by those to whom they are addressed, and economic operators are undoubtedly the first actors of its success. But the judges of the European Union, competent to settle disputes concerning the application of European Union law between the Member States, the European institutions, and individual applicants, may be also be involved in ensuring the effectiveness of European compliance rules and in interpreting them. -

Articles in The Journal of Regulation & Compliance « JoRC »

WENNERSTRÖM, Erik🕴️

📝Some Reflections on Compliance and the European Court of Human Rights, in 🕴️M.-A. Frison-Roche (ed.), 📘Compliance Jurisdictionalisation

► Full Reference: E. Wennerström, "Some Reflections on Compliance and the European Court of Human Rights", in M.-A. Frison-Roche (ed.), Compliance Jurisdictionalisation, Journal of Regulation & Compliance (JoRC) and Bruylant, coll. "Compliance & Regulation", to be published.  - 📘read a general presentation of the book, Compliance Jurisdictionalisation, in which this article is published   - ► Summary of the article (done by the Journal of Regulation & Compliance): The development of the European Court of Human Rights case law, contributing to European integration, has incorporated the substantial concept of ​​"compliance" which goes beyond the idea of ​​legality with respect to which companies remain passive, and promotes legal orders as systems in interaction with one another. The author develops the spirit and scope of Protocol 15 by which both the principle of subsidiarity and the margins of appreciation the signatory States are organized, mechanisms governed by the principle of proportionality. Subsidiarity means that the States are in the best position to design the most adequate application of the Convention, the close links between the States allowing its effective application. In addition, the new opinion procedure which allows a national court to have during a case the non-binding opinion of the ECHR ensures better compliance with the objectives of the Convention. The case-law of the Court takes up this substantial requirement through its doctrine, in particular identified in the Bosphorus case, by stressing that the accession of a State to the European Union presumes its compliance when implementing EU law with the obligations arising from the ECHR, even if this presumption can be refuted if the protection is manifestly lacking, which was admitted in several cases, in particular concerning the right to an impartial tribunal in matters of economic regulation. The different legal orders are thus articulated.  The author concludes that the European Court of Human Rights, like the Court of Justice of the Union, contributes to the construction of Compliance Law in Europe, from an Ex Ante perspective favoring opinions rather than Ex Post sanctions and creating, in particular through the Bosphorus doctrine, elements of security and confidence for European integration around common values. -   🦉This article is available in full text to those registered for Professor Marie-Anne Frison-Roche's courses -

Working papers

🚧 Conceiving Power

► Full reference: M.-A. Frison-Roche, Conceiving Power, Working Paper, December 2021 - 📝 This Working Paper serves as the basis for an article to be published in the collective book drawn up in tribute to Professor Emmanuel Gaillard.    - ► Working Paper summary: In 1985, Emmanuel Gaillard's central work came out under the title Le pouvoir en droit privé  (The Power in Private Law)📎1Gaillard, E., Le pouvoir en droit privé, préf. Cornu. G., coll. ..., Economica, 1985., but when it was defended in 1981, his thesis directed by Dean Cornu was entitled La notion de pouvoir en droit privé (The notion of Power in Private Law) 📎2Gaillard, E., La notion de pouvoir en droit privé, thèse .... ; . Let's give full force to the original title of the thesis.   The deletion of the term notion perhaps implies that by defining something the essential is done, that there would be something of a pleonasm in aiming at The notion of Power and The Power, as Law likes to economise on words.   But it was indeed a renewed, simpler and more powerful conception of the notion of Power, containing the entire regime necessarily imputed, that this work imposed, henceforth illuminating positive Law. Emmanuel Gaillard's definition, on the other hand, goes beyond Private Law. We would gladly have argued in favour of retaining the heading for the term Notion, proposing instead to dispense with the reference to Private Law alone …. Perhaps it was because the concept is so vast that in this seminal thesis its scope was restricted to Private Law, since the author already had to account for the sheer multiplicity of manifestations in this part of the legal system; Or perhaps it was because the concept of 'Power' is so familiar in Public Law that it would have needed less definition in Public Law (which, moreover, is so diversely proposed in this more political area, which is already careful on principle to distinguish between powers, which must always be plural in order to be separated), and that it was therefore reasonable to want to arrive at a single concept of Power in Private Law, where the notion of subjective rights is more familiar.  However, Emmanuel Gaillard's definition of Power as a prerogative placed, by legal rule or contract, in the hands of the person invested with them for the benefit, at least in part, of others, covers both Public and Private Law. This even contributes to the solidity of this thesis and explains why it flourishes today in legal systems where the distinction between Private Law and Public Law is weakening. The power of this definition lies in its simplicity. Simple and brave minds are often the most fruitful. As Dean Gérard Cornu points out in his preface, the author, in particular because he bases himself more on positive law, for example that relating to the powers of corporate officers, does not get bogged down in discussions between authors only to end up preferring one over the other. He arrives at a definition that is close to our everyday experience: the one we experience when we collect an envelope on behalf of someone else and the agent asks us in what capacity we claim to be doing this on his behalf. We then show him our 'power', the legal power to do so for the benefit of the person to whom the letter is addressed, and can thus exercise the power to withdraw the letter, even though it is personal. When legal and common sense come together, it is a good omen, not only in terms of form, because everyone can understand it and the Law must remain comprehensible, but also in terms of substance, because everyone must be able to control the exercise of a power that is exercised for and over others. For this letter addressed to someone else, the person who has been able to take it by virtue of the power conferred on him/her, could just as easily open it and read it, then destroy it or give it to the worst enemy of the person to whom it was addressed. In Power, there is always might to do, and the danger to others that Power contains therefore.  This highly legal definition of Power not only distances the holder from his/her own interests, but also channels the Power thus granted to the person who benefits from it. In this respect, Emmanuel Gaillard not only distinguished between Power and subjective right, but also identified the right amount of power required for this power to effectively fulfill this 'Mission', through the notion of abuse of power, when the holder uses for other beneficiaries this power that was conferred on him/her for this sole purpose. What is more, this concept makes it possible to distinguish Power from discretionary force, because the holder of Power thereby exercises factual , by acting for others, deciding for others, deciding on others. Because Power is inseparable from might, but might must remain the means of power and no more, the Law shall produce the antibodies that are not only the theory of abuse of power but also an Ex Ante responsibility that accounts must always be rendered, either to the other for whom everything is done or to a third party. For this third party is often there from the outset, the guardianship judge for example: because the Power was put in place because of the beneficiary's weakness, both in himself/herself and because of the situation, an impartial and disinterested third party is needed to ensure proper execution from the outset, without there even being a dispute. In this respect, how useful this thesis is for thinking about what Supervision is today!   This thesis, so clear, so simple and so strong, goes beyond Private or Civil Law. It is both much more restrictive than the more factual and political definition of Oower, which would be the ability to do something, and much broader than the usual definitions, since it embraces and legitimises de jure all situations where a person acts legally for the benefit of another.  Dean Cornu shows, moreover, in two sentences that such a notion of power also captures the office of the judge, who has power over others only to serve them 📎3"En droit processuel, l'office du juge aurait donné à l'auteur un renfort. Pour le juge, il n'est point de pouvoir sans devoir. Au-delà de la distinction de ce qu'il a obligation de faire ou faculté d'apprécier, il y a toujours, au creux de ce qu'il peut, le sceau de ce qu'il doit, un devoir gardien - comme un âme - de l'exercice du pouvoir." (p.5).. The definition corresponds to the mission of one who has power only to fulfill his office. It suits so well the conception we have today of Administration, especially if it takes the form of independent authorities. Moreover, Power thus contains its own limit in its very definition, since others are present in it: the holder has power only to serve others. From then on, it is only a power because it is a kind of Charge. Emmanuel Gaillard immediately uses the term: "Un individu se voit confier une charge qu'il exerce dans un intérêt au moins partiellement distinct du sien propre"  ("An individual is entrusted with an office which he exercises in an interest at least partially distinct from his own") 📎4n°3, p.9. . Dean Carbonnier, who reformed the legislation in this area 📎5🕴️J. Carbonnier, 📗Essai sur les lois, 1992 (on the guardianship).,, emphasised that the guardian has a public duty because the State entrusts him/her with a child. In the same way parental authority is a charge on the parents for the benefit of the children. More generally, Power is a burden that the Law places on a person to satisfy the interests of another. This definition offered by Emmanuel Gaillard in 1981, anchored in Private Law only insofar as it is the entire legal system, is premonitory of the Regulatory and Compliance Law as it unfolds today. It would be enough to continue the Gaillard's sentences, as if they had been half-written, to finish them 40 years later and find in them the mechanisms of Supervision of companies by public authorities which are now in place not to reduce their power but to ensure that they exercise it for the benefit of others 📎6S. in a general way, 🕴️M.-A. Frison-Roche (ed.), 📕Régulation, Supervision, Compliance, 2017.. The whole evolution of Company Law and Financial Law is here. Between the lines of this thesis, which develops the notion of duty 📎7Cornu, préface précitée : "Tous les pouvoirs sont, à double face, des pouvoirs-devoirs" (p.5)., we can also see what positive Law is developing today, in particular through the 'duty of Vigilance', this personal responsibility for the benefit of others (I). The definition of Power thus conceived contains within itself its regime and enables us to anticipate it better today: because the holder exercises Power only for others, at least partially, he is consubstantially accountable for it, responsibility being only one form of this accountability; because this service must be effective and others must benefit fully from it, because unlike the subjective right which allows the holder freely not to use his might, Power has never been the 'most absolute' availability to use his/her might: it is even the opposite. It is the expression of a Power assigned to a purpose, compelling the holder to use his/her Power to that end.  But it is equally necessary for the holder to have all the might to do so, otherwise the very notion of 'Power' is meaningless. This is the definition that should be given to the principle of Proportionality: the person on whom the Power rests must have not more power than is necessary, but all the power necessary to achieve the Monumental Goals for which the Power has been entrusted to him/her, so that others may derive full benefit from it (II).  In today's positive Law, the definition of Power as a Duty is found not only in Private Law but also in Public Law, not least because pure might, i.e. those that do not account for the use of their might, are in decline while concern for others is on the increase. The days of discretionary powers are over, and the increased independence of those who exercise Power over others requires them to be accountable. Beyond this Accountability, the personal Responsibility of those who have the Power to serve others is being established. But, no doubt because the Law is slow to evolve, the correlative idea that the holder of Power must have all the powers required to carry out his/her mission is less entrenched:  As Emmanuel Gaillard has shown, the Law has only gone part of the way in sanctioning excesses of power, when the holder uses his/her power for other goals, but it has not yet clearly established that the holder – sometimes forced – of a Power is legitimate in using all the means required to achieve the result for which this Power, i.e. a charge and a duty, has been conferred on him/her.   No doubt we need to read Emmanuel Gaillard's thesis again in all its potential, to imagine the reading we could do today of what he could have written as if on blank pages that would write themselves, a magical thesis where everything is already there, a thesis so short (250 pages) and so beautiful, so dense that it already contains the Law of the Future. The Law of the Future 📎8On Compliance Law as a Law of the Future, s. 🕴️M.-A. Frison-Roche, 📝Compliance Monumental Goals, beating heart of Compliance Law, in 🕴️M.-A. Frison-Roche (ed.), 📘Compliance Monumental Goals, 2023. On the consequences for Liability Law, which is now looking to the Future, s. 🕴️M.-A. Frison-Roche, 🚧Ex Ante Responsibility, 2021.  where there must be much more responsibility for the benefit of others📎9Sur la notion de "Responsabilité Ex Ante", v. Frison-Roche, M.-A., La responsabilité Ex Ante", in Archives de Philosophie du Droit, La responsabilité, 2022. and powers since this notion includes others who are the beneficiaries. Droit de l'Avenir where Emmanuel Gaillard will be present, in particular thanks to this work of doctrine offered in 1981.  So that, in practical terms, those who are entrusted with looking after others – for example, today all companies obliged by Compliance Law to look after others so that they are not destroyed by hatred in the digital space, by corruption in the economic system or by climate change in a projected future – do not find themselves challenged by the same Law for the means of exercising this power for the benefit of others, for example when this involves 'judging'. Dean Cornu himself emphasised the identity of the two offices. -                         Lire les développement ci-dessous⤵ - 🌐 follow Marie-Anne Frison-Roche on LinkedIn 🌐follow Marie-Anne Frison-Roche on Instagram 🌐subscribe to the Newsletter MAFR Regulation, Compliance, Law 

Working papers

Working Paper

🚧The Hypothesis of the category of Systemic Cases brought before the Judge

► Full Reference: M.-A. Frison-Roche, The Hypothesis of the category of Systemic Cases brought before the Judge, Working Paper, October 2021 and April 2022. - ► This working paper has served as the basis for an introductory speech 🎤L'hypothèse de la catégorie des causes systémiques (The Hypothesis of the cateory of Systemic Cases), in a more general conference which I coordinated and moderated, 🧱L'office du juge et les causes systémiques, which is part of a general cycle covering Penser l'office du juge, specific conference attending the 9th May 2002 into the Grand Chamber of the Cour de cassation.   This Working Paper was drawn up in October 2021 to build the conference on the assumption that among the diversity of "cases" brought to the courts by litigants, some constitute a specific category: "systemic cases", justifying treatment that is both specific (in that they are systemic, calling in particular for procedural solutions common to all and distinguishable from the treatment of non-systemic cases) and common treatment beyond the diversity of judges who deal with them (judicial and administrative judges, criminal and non-criminal judges, French and non-French judges, judges of the member-States legal orders and European Union judges, etc.).  This working paper does not aim to deal with the whole subject, i.e. both to determine this category of "systemic causes" and the consequences that must be drawn from it for the judge's office, since that is the very purpose of the conference, which is built around several presentations: it aims to deal with the first part of the subject, i.e. the very existence of this new processual category, which is "systemic causes", leaving for other work the practical consequences to be drawn from it in the processual treatment that it calls for. - 📝This Working Paper is also the basis of a forthcoming article - ► Summary of the Working Paper: xx - Read below the developments⤵️ - 🌐follow Marie-Anne Frison-Roche on LinkedIn 🌐follow Marie-Anne Frison-Roche on Instagram 🌐subscribe to the Newsletter MAFR. Regulation, Compliance, Law

Working papers

🚧Reinforce the Judge and the Attorney to impose Compliance Law as a characteristic of the Rule of Law

► Full Reference: Frison-Roche, M.-A, Reinforce the judge and the lawyer to impose Compliance Law as a characteristic of the Rule of Law, Working Paper, August 2021. - 🎤 this working document has been made to prepare some elements of the opening intervention in the symposium Quels juges pour la Compliance) ? (Which judges for Compliance?), co-organized by the Journal of Regulation & Compliance and the Institut Droit Dauphine, held at the Paris Dauphine University on September 23, 2021, constituting the first part of the intervention. - 📝it has been also the basis for an article:  📕 published in its French version in the book La juridictionnalisation de la Compliance, in the collection📚Régulations & Compliance  📘published in its English version in the book Compliance Jurisdictionalisation, in the collection 📚Compliance & Regulation - ► Summary of the Working Paper: One can understand that the compliance mechanisms are presented with hostility because they seem designed to keep the judge away, whereas there is no Rule of Law without a judge. Solid arguments present compliance techniques as converging towards the uselessness of the judge (I). Certainly, we come across magistrates, and of all kinds, and powerful ones, but that would be a sign of imperfection: its ex-ante logic has been deployed in all its effectiveness, the judge would no longer be required… And the lawyer would disappear so with him… This perspective of a world without a judge, without a lawyer and ultimately without Law, where algorithms could organize through multiple processes in Ex Ante the obedience of everyone, the "conformity" of all our behaviors with all the regulatory mass that is applicable to us, supposes that this new branch of Law would be defined as the concentration of processes which gives full effectiveness to all the rules, regardless of their content. But supposing that this engineer's dream is even achievable, it is not possible in a democratic and free world to do without judges and lawyers. Therefore, it is imperative to recognize their contributions to Compliance Law, related and invaluable contributions (II). First of all, because a pure Ex Ante never existed and even in the time of the Chinese legists1 L’empire chinois n’a semble-t-il jamais apprécié les juges, ne leur faisant place que sous la forme de serviteurs purs de l’Etat, qu’ils soient des enquêteurs, des punisseurs et de gardiens de l’ordre public. Sur cet aspect du Droit chinois, v. … ; sur cette période particulièrement sanglante des légistes, où le principe de « certitude » de la législation a été portée à ses nues, v. …, people were still needed to interpret the regulations because a legal order must always be interpreted Ex Post by who must in any case answer the questions posed by the subjects of law, as soon as the political system admits to attributing to them the right to make claims before the Judge. Secondly the Attorney, whose office, although articulated with the Judge's office, is distinct from the latter, both more restricted and broader since he must appear in all cases where the judicial figure puts himself in square, outside the courts. However, Compliance Law has multiplied this since not only, extending Regulatory Law, it entrusts numerous powers to the administrative authorities, but it also transforms companies into judges, in respect of which the attorneys must deal with. Even more so, Compliance Law only takes its sense from its Monumental Goals2🕴️Frison-Roche, M.-A. (ed.), 📘​Compliance Monumental Goals, 2022.. It is in this that this branch of the Law preserves the freedom of human beings, in the digital space where the techniques of compliance protect them from the power of companies by the way that the Compliance Law forces these companies to use their power to protect people. However, firstly, it is the Judges who, in their diversity3The topic of this study is general. For a more analytical perspective, s.. 🕴️Frison-Roche, M.-A., « The function of the Judge in Compliance Law », in 🕴️Frison-Roche, M.A. (ed.), 📘Compliance Jurisdictionalisation, 2023. , impose as a reference the protection of human beings, either as a limit to the power of compliance tools4🕴️Frison-Roche, M.-A. (ed.), 📘Compliance Tools, 2021.  or as their very purpose. Secondly, the Attorney, again distinguishing himself from the Judge, if necessary, reminds us that all the parties whose interests are involved must be taken into consideration. In an ever more flexible, soft and dialogical Law, everyone presenting himself as the "advocate" of such and such a monumental goal: the Attorney is legitimate to be the first to occupy this place. - 🔓read the Working Paper developments below⤵️

Breaking news

📧 COMPLIANCE: LAW IS SLOW, BUT FIRM. BY ITS JUDGMENT OF JUNE 15, 2021, “FACEBOOK”, THE EUROPEAN UNION COURT OF JUSTICE WIDELY INTERPRETS THE POWER OF NATIONAL AUTHORITIES SINCE IT SERVES THE PROTECTION OF PEOPLE IN THE DIGITAL SPACE

► Law is slow, but firm. By its judgment of June 15, 2021, Facebook , the European Union Court of Justice widely interprets the powers of National Authorities, since they serve the people protection in the digital space (➡️📝(CJEU, June 15, 2021, Facebook).    Law is slow. The reproach is so often made. But the bottom line is that, in the noise of changing regulations, it establishes clear and firm principles, letting everyone know what to stand for. The more the world is changing, the more Law is required. When Law degenerates into regulations, then it is up to the Judge to make Law. "Supreme Courts" appear, de jure as in the United States, de facto as in the European Union by the Court of Justice of the European Union which lays down the principles, before everyone else, as it did for the "right to be forgotten" in 2014 (➡️📝CJEU, Google Spain, May 13, 2014), and then with the impossibility of transferring data to third countries without the consent of the people concerned (➡️📝CJEU, Schrems, October 6, 2015). Facebook litigation is kind of a novel. The company knows that it is above all to the Courts that it speaks. In Europe, it is doing it behind the walls of the Irish legal space, from which it would like to be able not to leave before better dominating the global digital space, while national regulatory authorities want to take it to protect citizens. There is therefore a technical question of "jurisdictional competence". The texts have provided for this, but Law is clumsy because it was designed for a world still anchored in the ground: the GDPR of 2016 therefore organizes cooperation between national regulatory authorities through a "one-stop-shop", forcing the authorities to relinquish jurisdiction so that the case is only handled by the "lead" National Authority. This avoids splintering and contradiction. But before the adoption of the GDPR, the Belgian data protection regulator had opened a procedure against Facebook concerning cookies. The "one-stop-shop" mechanism, introduced in 2016, is therefore only mentioned before the Brussels Court of Appeal, which is asked to relinquish jurisdiction in favor of the Irish Regulatory Authority, since the company has in Europe its head office in this country. The Court of Appeal referred to the CJEU for a preliminary ruling. By its judgment of June 15, 2021 (➡️📝CJUE, Facebook, June 15, 2021), it follows the conclusions of its Advocate General and maintains the jurisdiction of the Belgian National Regulator because, even after the GDPR, the case still undergoes national treatment. In this decision, the most important is its reasoning and the principle adopted. The Court notes that the "one-stop-shop" rule is not absolute and that the national regulatory authority has the power to maintain its jurisdiction, in particular if cooperation between national authorities is difficult. Even more, will it not one day have to adjust Law more radically? We need to consider the fact that the digital space is not bound by borders and that the ambition of "cross-border cooperation" is ill-suited. It is of course on this observation of inefficiency, consubstantial with the digital space, that the European Public Prosecutor's Office (EPPO) was designed and set up, which is not a cooperation, nor a "one-stop shop", but a body of the Union, acting locally for the Union, directly linked to Compliance concerns (➡️📝Frison-Roche, M.-A. "The European Public Prosecutor's Office is a considerable contribution to Compliance Law", 2021 and ., European Public Prosecutor's Office comes on stage: the company having itself become a private prosecutor, are we going towards an alliance of all prosecutors ?, 2021). So that's what we should be inspired by.

Conferences

🎤 Note taken during the colloquium “Compliance and Arbitration” for doing its conclusion: a backing (Conclusion, in “Compliance and Arbitration))

Full reference: Frison-Roche, M.-A., Compliance et arbitrage. Rapport de synthèse: un adossement (Compliance and Arbitration: a Backing. Conclusion), in Frison-Roche, M.-A. & Racine, J.-B., Compliance et Arbitrage (Compliance and Arbitration), Colloquium co-organised by the Journal of Regulation & Compliance (JoRC) and the Centre de recherches sur la Justice et le Règlement des Conflits (CRJ) of Panthéon-Assas University (Paris II), with the support avec the International Court of Arbitration, Paris, 31st of March 2021 -   Read the program of this colloquium See Marie-Anne Frison-Roche's conclusion in video (in French, with English subtitles) These notes of the conclusion have been written as the colloquium took place.  See the video of the entire colloquium (in French, with English subtitles) - This colloquium is part of the Cycle of colloquium 2021 organized by the Journal of Regulation & Compliance (JoRC) and its partners around the topic Compliance Juridictionnalization.   This manifestation is in French but the interventions will be the basis for a specific chapter of the English collective book directed by Marie-Anne Frison-Roche, Compliance Juridictionnalization, co-published by the JoRC and Bruylant. An equivalent book in French, La Juridictionnalisation de la Compliance, directed by Marie-Anne Frison-Roche, will be co-published by the JoRC and Dalloz.    Read the notes established for the conclusion below ⤵️

Articles

Due process and Personal Data Compliance Law: same rules, one Goal (GCEU, October 29, 2020 Order, Facebook Ireland Ltd v/ E.C.)

Full reference: Frison-Roche, M.-A., Due process and Personal Data Compliance Law: same rules, one Goal (CJEU, Order, October 29, 2020, Facebook Ireland Ltd v/ E.C.), Newsletter MAFR – Law, Compliance, Regulation, 1st of November 2020 Read by freely subscribing other news of the Newsletter MAFR – Law, Compliance, Regulation Read Marie-Anne Frison-Roche's interview in Actu-juridiques about this decision (in French)   Summary of the news:  As part of a procedure initiated for anti-competitive behaviors, the European Commission has three times requested, between the 13th of March and the 11th of November 2019, from Facebook the communication of information, reitarated in a decision in May 2020.   Facebook contests it alleging that the requested documents would contain sensitive personal information that a transmission to the Commission would make accessible to a too broad number of observers, while "the documents requested under the contested decision were identified on the basis of wideranging search terms, (…) there is strong likelihood that many of those documents will not be necessary for the purposes of the Commission’s investigation".  The contestation therefore evokes the violation of the principles of necessity and proportionality but also of due process because these probatory elements are collected without any protection and used afterwards. Moreover, Facebook invokes what would be the violation of a right to the respect of personal data of its employees whose the emails are transferred.  The court reminds that the office of the judge is here constraint by the condition of emergency to adopt a temporary measure, acceptable by the way only if there is an imminent and irreversible damage. It underlines that public authorities benefit of a presumption of legality when they act and can obtain and use personal data since this is necessary to their function of public interest. Many allegations of Facebook are rejected as being hypothetical.  But the Court analyzes the integrality of the evoked principles with regards with the very concrete case. But, crossing these principles and rights in question, the Court estimates that the European Commission did not respect the principle of necessity and proportionality concerning employees' very sensitive data, these demands broadening the circle of information without necessity and in a disproportionate way, since the information is very sensitive (like employees' health, political opinions of third parties, etc.).  It is therefore appropriate to distinguish among the mass of required documents, for which the same guarantee must be given in a technique of communication than in a technic of inspection, those which are transferable without additional precaution and those which must be subject to an "alternative procedure" because of their nature of very sensitive personal data.  This "alternative procedure" will take the shape of an examination of documents considered by Facebook as very sensitive and that it will communicate on a separate electronic support, by European Commission's agents, that we cannot a priori suspect to hijack law. This examination will take place in a "virtual data room" with Facebook's attorneys. In case of disagreement between Facebook and the investigators, the dispute could be solved by the director of information, communication and medias of the Directorate-General for Competition of the European Commission.  - We can draw three lessons from this ordinance:  This decision shows that Procedural Law and Compliance Law are not opposed. Some often say that Compliance guarantees the efficacy and that Procedure guarantees fundamental rights, the protection of the one must result in the diminution of the guarantee of the other. It is false. As this decision shows it, through the key notion of sensitive personal data protection (heart of Compliance Law) and the care for procedure (equivalence between communication and inspection procedures; contradictory organization of the examination of sensitive personal data), we see once again that two branches of Law express the same care, have the same objective: protecting people.  The judge is able to immediately find an operational solution, proposing "an alternative procedure" axed around the principle of contradictory and conciliating Commision's and Facebook's interests has shown that it was able to bring alternative solutions to the one it suspends the execution, appropriate solution to the situation and which equilibrate the interest of both parties.  The best Ex Ante is the one which anticipate the Ex Post by the pre-constitution of evidence. Thus the firm must be able to prove later the concern that it had for human rights, here of employees, to not being exposed to sanctioning pubic authorities. This Ex Ante probatory culture is required not only from firms but also from public authorities which also have to give justification of their action.    -    

Articles

Freedom&Media:when Italian Media Regulation’s real “goal”​ is not Pluralism Protection, Freedom of Establishment prevails (CJEU, 3 Sept.2020,Vivendi)

Full reference: Frison-Roche, M.-A., Freedom&Media: when Italian Media Regulation's real "goal"​ is not Pluralism Protection, Freedom of Establishment prevails (CJEU, 3 Sept.2020,Vivendi), Newsletter MAFR – Law, Regulation, Compliance, 9th of September 2020 Read by freely subscribing other news of the Newsletter MAFR – Law, Regulation, Compliance   Summary of the news The media sector is organized on an equilibrium between the principle of competition and other concerns like information pluralism. Generally, competition Law by making market accessible to many competitors ensures information pluralism. But, this is not the case if an operator get an excessive market power, running risk not only for competition but also for information pluralism. It is the reason why the Italian legal system forbids the constitution of an operator gathering more than 40% of the total income generated by the media sector or more than 10% of the total income generated by the Italian communication sector.  In 2016, Vivendi, a French media group, got more than 28% of the Mediaset Group's actions and around 30% of its voting right. The Italian communication regulation authority sized by Mediaset demands in 2017 to Vivendi to ends its participations in the group Mediaset. Vivendi contested this decision before the regional administrative court which referred to the Court of Justice of the European Union in order to know if freedom of establishment can legitimately be discarded in favor of information pluralism in this concrete case. The Court of Justice answered, in a decision of 3rd of September 2020, that the restriction of the freedom of establishment can in principle be justified by a general interest objective such as information pluralism protection but that in this concrete case, this is not justified because the fact that a firm is committed in the transmission of contents does not necessarily give it the power to control the production of such contents. We can learn three lessons form this case: The Court precises that even if the principle is the freedom of establishment, it is possible to discard it to protect information pluralism protection under the condition that the concerned member State do not use this legitimate power to create a political monopoly, the burden of proof falling on the person attacking national legislation and not on the Member State. The Court distinguishes transmission of contents and production of contents and explains that if the State rejects this decision, the burden falling to it to prove the concrete links between these two activities. This case shows that the power to share the respective places of the "principle" and of the "exception" always comes back to the judges.