SOURCE 0 : ANTI-CORRUPTION COMPLIANCE AND THE PROOF GAP

The new anti-corruption directive shifts liability from "who committed the infraction" to "why didn't your organisation prevent it." Demonstrating that a compliance programme functioned requires proof it was operational before the act — not documentation assembled after. With sanctions reaching 5% of global turnover or 40 million euros, this article establishes why that distinction is architectural, not procedural.