Internal investigations have become a central arena of contemporary governance. By establishing facts: they reveal legal cultures, institutional tensions, and the underlying conceptions of truth that shape organizations. In a world where companies operate simultaneously under multiple legal sovereignties, the internal investigation has become the place where factual integrity is tested — that is, the ability to produce facts that are reliable, traceable, and interpretable despite the diversity of legal models.

Internal Investigations: France, Europe, United States — Three Models, Three Cultures, One Demand for Factual Integrity

Understanding internal investigations means understanding organizations. Understanding the models means understanding the tensions that shape decision-making.

Internal investigations have become a central aspect of contemporary governance. They are no longer limited to establishing facts; they reveal legal cultures, conceptions of truth, and organization dynamics that shape organizations. 

In an environment where companies operate simultaneously under multiple legal jurisdictions, understanding the American, European, and French Models is no longer a theoretical exercise; it has become an essential analytical lens for producing decisions that are coherent, defensible, and usable across jurisdictions.

Internal investigations do not rest on a unified legal framework. They are the product of distinct legal, organizational, and behavioral cultures. Since the early 2000s, the rise of American extraterritoriality — illustrated by high‑profile cases targeting European and French companies (Siemens, Alstom, Technip, Total) — has reinforced the idea of  competition between models: a clash between American transactional efficiency, European proportionality requirements, and French evidentiary rigor. This narrative, fueled by debates on sovereignty and economic warfare, suggests that each system seeks to impose itself at the expense of the others.

A closer look at actual practices reveals a different reality. One may even ask whether the real interest for companies, authorities, and practitioners lies not so much in the competition between systems, but in their articulation. Each model appears to carry its own strength: efficiency and risk management in the United States, proportionality and documentation in Europe, evidentiary fairness and methodological rigor in France. Taken in isolation, none of these approaches is sufficient. Taken together, they produce internal investigations that are more robust, more balanced, and more defensible.

Understanding these differences — and how their mutual and respective influence shapes the internal investigation process — provides an indispensable analytical lens for producing decisions that are coherent, defensible, and usable across jurisdictions.

Three ideas structure this article and offer a way to read internal investigations beyond the contrasts between systems:

• An internal investigation is not a neutral act per se: it reflects the values, constraints, and priorities of the system conducting it.
• Factual integrity is a key element of fairness and due process in internal investigations: the ability to produce facts that are reliable, traceable, and interpretable, regardless of pressures, biases, or the legal models involved.
• Hybrid internal investigations contribute to achieving factual integrity and support the administration of justice, as they rely on complementary legal cultures and methods.

These three pillars help explain not only the differences between models, but also how they can complement one another to secure decision‑making in transnational environments.

The observations and analyses presented here focus on the American, European, and French Models. This choice in no way diminishes the value of approaches developed in other legal systems, which could usefully complement this comparative perspective.
 

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I. The American Model gives priority to Efficiency, Cooperation, and Negotiation

1.1 Context of emergence

Internal investigations emerged in the United States in the 1970s, in a context shaped by corruption and governance scandals revealed in the aftermath of Watergate. Over time, they became structured under the influence of federal authorities, particularly the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC).

With the adoption of the Foreign Corrupt Practices Act (FCPA) in 1977, and the strengthening of its enforcement from the 1990s onwards, a culture of self‑disclosure developed within large corporations. By cooperating with the authorities and implementing remediation measures, companies were able to limit their criminal and reputational exposure.

1.2 Structuring logics 

In this context, mechanisms of negotiated settlements emerged, notably Deferred Prosecution Agreements and Non‑Prosecution Agreements. Behind these mechanisms lies a central objective: speed and efficiency. Companies are able to produce relevant documentation quickly and adopt a proactive cooperative posture, counterbalancing a strong risk‑management culture.

Within this model, investigative lawyers play a central role in collecting, reviewing, and analyzing documentary evidence. The American internal investigation follows a transactional logic, oriented towards dispute resolution and negotiation with the authorities.

Competition law holds a particular place within the American Model of internal investigations. It has significantly shaped self‑reporting and cooperation practices, notably through the leniency programmes implemented by the Department of Justice Antitrust Division.

The internal investigation becomes a strategic tool enabling the company to identify facts quickly, document anti‑competitive behavior, and position itself early within a cooperative framework with the authorities. The speed of evidence collection and analysis directly determines access to leniency mechanisms or reduced sanctions.

1.3 Tensions and limitations

The American Model carries its own tensions and limitations. The pursuit of efficiency and cooperation may conflict with requirements relating to the protection of individuals, procedural fairness, and the management of civil liability risks — particularly in the context of follow‑on litigation or class actions.

Competition law illustrates this dynamic in a particularly acute way: the American internal investigation often operates as a transactional instrument — a risk‑management and negotiation tool whose value depends closely on the quality, speed, and credibility of the factual work carried out.

1.4 Effects on Investigative Practice

It would, however, be inaccurate to suggest that the American Model prioritizes speed and efficiency at the expense of due process. The US system places due process at its core, but due process is exercised primarily before the courts, at the stage of adversarial proceedings, and not within the internal investigation itself. The American internal investigation is not designed as a space for procedural safeguards: it operates within a logic of risk management and cooperation with the authorities, in which the company rapidly produces a factual narrative intended for negotiation. 

Due process rights are not ignored; they intervene downstream, within the judicial process, rather than upstream, as in the French Model, where the internal investigation is already an evidentiary exercise subject to requirements of fairness and adversarial balance. This difference in the timing of procedural safeguards explains the predominant emphasis placed, in the United States, on efficiency and cooperation in the conduct of internal investigations.

The American Model therefore rests on a clear separation between the internal investigation — a risk‑management tool — and the judicial process, where due process is fully exercised. The latest updates to the DOJ’s Corporate Enforcement Policies (2023) confirm this orientation: the speed of factual production, the quality of cooperation, and the company’s ability to demonstrate credible remediation remain decisive criteria in the assessment conducted by US authorities.

II. The European Model Shaped by Objectives of Protection, Proportionality, and Documentation

2.1 A Constrained and Regulated Importation

Internal investigations did not emerge in Europe as an autonomous tool of governance or negotiation with the authorities. They developed gradually and unevenly, driven by specific external and sector‑based pressures.

In the 2000s, the practice of internal investigations became unavoidable for European companies exp

osed to the extraterritorial reach of US law, particularly in the context of investigations conducted by the Department of Justice and the Securities and Exchange Commission. The need to meet their requirements relating to cooperation, document review, and the production of reliable facts led international groups to structure internal investigation mechanisms, often inspired by American standards.

In parallel, the European Union strengthened its own compliance requirements, particularly in regulated sectors, through obligations relating to anti‑money laundering and counter‑terrorist financing, market‑abuse prevention, competition law, and data protection. Internal investigations then emerged as a tool for risk management and for demonstrating compliance.

Finally, the development of internal reporting mechanisms and the protection of whistleblowers contributed to institutionalizing internal investigations as a structured process for handling alerts, governed by strict procedural safeguards. The European internal investigation thus developed primarily as a compliance and protection tool, rather than as an instrument of negotiation.

2.2 A Model Structured by Cross‑Cutting Norms

To date, the European Union has not established a unified regime for internal investigations. Nevertheless, it exerts a decisive influence on their conduct through a set of overarching norms that tightly regulate practice.

Three pillars now structure the European Model.

The first is the General Data Protection Regulation (GDPR), which imposes strict rules on the collection, processing, retention, and transfer of personal data. The legitimacy of an internal investigation is inseparable from compliance with the principles of proportionality, data minimization, and traceability — requirements that have been further reinforced by recent EDPB guidance and national decisions, as well as by the evolving framework governing international data transfers.

The second pillar is the Whistleblower Protection Directive (Directive 2019/1937), now implemented across Member States. It requires organizations to establish internal reporting channels, to process alerts within defined timelines, and to provide procedural safeguards designed to protect the individuals concerned. These obligations have significantly formalized the treatment of alerts and the documentation of investigative steps.

Finally, a set of sector‑specific directives — notably in the fields of anti‑money laundering and counter‑terrorist financing, financial services, competition law, digital services (DSA), digital markets (DMA), cybersecurity (NIS2), and crypto‑assets (MiCA) — complements this framework and reinforces compliance obligations. These instruments increasingly require structured fact‑finding, documented risk assessments, and coordinated engagement with national authorities.

Within this model, the internal investigation is above all a procedural compliance exercise. Documentation, justification of methodological choices, and the protection of individual rights occupy a central place. The objective is less negotiation than the demonstration of compliance with applicable norms and coordination with the competent national authorities. It is a protective model, centered on fundamental rights and the integrity of processes — a model whose contours have only become more pronounced with recent regulatory developments.

2.3 The Introduction of Internal Investigations: A Silent Driver of Change in European Legal Systems ?

The introduction of internal investigations in Europe and in France raises a deeper question. One may wonder whether this tool—imported under the pressure of American extraterritoriality—might have ultimately acted as a silent driver of change within our legal systems. In other words, did the internal investigation contribute to introducing into European and French Models certain logics of negotiation, cooperation, and transactional resolution that are closer to the American approach?

This hypothesis does not stem from a strategic or intentional reading, but from a structural observation: when a tool is widely used in a transnational context, it inevitably carries with it the representations, methods, and objectives of the system in which it originated. Internal investigations may therefore have operated as a discreet normative “Trojan Horse”, gradually diffusing risk‑management reflexes and dispute‑resolution practices that do not, at their origin, align with European and French evidentiary and procedural logics.

Recent regulatory developments nuance this dynamic. The implementation of the Whistleblower Protection Directive, the reinforcement of GDPR enforcement, and the emergence of new sector‑specific regimes — including the Digital Services Act, the Digital Markets Act, NIS2, MiCA, and the updated anti‑money‑laundering framework — have significantly strengthened the procedural and rights‑based foundations of internal investigations in Europe. These instruments confirm that, while internal investigations may introduce negotiation‑oriented logics, they are increasingly embedded within a compliance architecture that reflects European legal culture.

This question sheds even greater light on the singularity of the French Model, built precisely in response to these influences, by reaffirming the centrality of fairness, adversarial balance, and the admissibility of facts. France has developed an approach that integrates the operational benefits of internal investigations while preserving — and now expressly structuring — the structural guarantees of its evidentiary tradition, notably through the 2026 legislative framework on internal investigations and recent case law clarifying their procedural status.

Ultimately, the internal investigation appears both as a revealing lens of legal cultures and as the space in which factual integrity is tested. Factual integrity refers to the ability of an investigation to produce facts that are reliable, traceable, and interpretable, regardless of pressures, biases, or the legal models at play.

III. The French Model of Internal Investigations Places Evidence Law, Fairness, and Adversarial Balance at the Centre of the Framework

3.1 Context of Emergence

France did not adopt internal investigations by mimicking the American Model or by simply transposing European requirements. Their development resulted from a combination of factors specific to the French legal and institutional environment.

First, French companies were confronted with the extraterritorial reach of US law, particularly in matters of international corruption, economic sanctions, and competition. Investigations conducted by the DOJ and the SEC revealed the need, when responding to US authorities, to have internal mechanisms capable of establishing facts rapidly while respecting — and ensuring respect for — the requirements of French evidence law.

Second, the emergence of a French compliance framework — strengthened by the Sapin II Act, the creation of the French Anti‑Corruption Agency (AFA), and the introduction of the judicial public interest agreement (CJIP) — made it essential for companies to be able to conduct internal investigations that are credible, traceable, and aligned with the expectations of French authorities.

Finally, French practitioners of internal investigations have pushed back against the American approach, which prioritizes a culture of negotiation and speed. It is in this context that a distinctly French law of internal investigations has emerged, centered on evidentiary fairness, respect for adversarial balance, the protection of individuals, and coordination with criminal procedure. This evolution has been further consolidated by the 2026 legislative framework on internal investigations, which defines their regime, clarifies the role of counsel, and strengthens procedural safeguards.

As a result, this developing French framework appears to render American standards less operational and European standards insufficient. France has therefore had to construct an autonomous model, focused on the quality of factual work and the evidentiary robustness of the material collected.

The French Model reflects the need to reconcile compliance requirements with the fundamental principles of civil, criminal, and administrative procedure, as well as the protection of individuals guaranteed under French law.

3.2 A Model initially shaped by Case Law and Administrative Authorities

French case law has imposed high standards in matters of evidentiary fairness (loyauté de la preuve), respect for adversarial balance (respect du contradictoire), impartiality, and methodological rigor. These principles permeate every stage of the internal investigation process: the collection of information, interviews, factual analysis, and the drafting of conclusions.

It is now clear that the internal investigation intersects labour law, criminal law, and evidence law. Recent decisions from labour and criminal courts have reinforced this requirement: the admissibility of material produced through an internal investigation now depends as much on the fairness of its collection as on the respect for the rights of the individuals interviewed. At the same time, case law has clarified the procedural status of internal investigations, distinguishing them from disciplinary proceedings and criminal trials, and confirming that while full adversarial debate is not required at the investigative stage, fairness and respect for rights remain central to judicial assessment.

Several independent administrative authorities play a structuring role:

• the French Anti‑Corruption Agency (AFA), which oversees compliance frameworks and methodological expectations,
• the CNIL, which imposes strict rules on the collection and processing of data and on the proportionality and traceability of investigative measures,
• the Defender of Rights, which ensures the protection of rights and freedoms within organizations and scrutinizes internal mechanisms when they affect individuals.

These requirements converge toward a the idea that the value of an internal investigation depends on the quality of the factual work and the fairness of the process.

3.3 A Legislative Framework in the Making

A specific legislative framework is currently being developed to introduce, for the first time in France, a legal status for internal investigations. The Proposal for a Law of 9 December 2025 (Proposition de loi n° 2208), now under examination in the National Assembly, aims to provide a statutory definition of internal investigations, regulate interviews, strengthen procedural safeguards, and articulate internal investigations with criminal procedure.

The emergence of this proposal reflects a convergence of practical and institutional needs. The growing use of internal investigations in labour matters, compliance programs, anti‑corruption controls, competition law, digital regulation, and cybersecurity has exposed the limits of a framework based almost exclusively on case law. Courts have repeatedly been required to assess the admissibility of evidence produced through internal investigations, often without explicit statutory guidance, creating uncertainty for companies, practitioners, and individuals.

The rise of negotiated justice mechanisms, particularly the CJIP, has further highlighted the need for factual material that is both operationally useful and legally robust. French authorities increasingly rely on internal investigations to assess corporate behaviour, yet the absence of a statutory regime has generated tensions between compliance expectations and procedural guarantees.

Finally, the diffusion of internal investigations under American and European influences has raised structural concerns. While the tool was imported into France through transnational pressures, its methods and objectives do not always align with the principles of fairness, adversarial balance, and evidentiary loyalty that define French procedure. The proposal therefore seeks to acknowledge the operational need for internal investigations while molding it to the French legal framework, transforming an imported practice into a mechanism governed by France’s own procedural culture, evidentiary tradition, and constitutional safeguards. The ongoing parliamentary process thus reflects a broader assertion of legal sovereignty.

3.4 A Demanding Evidentiary Model

In the French LegaModel, the internal investigation is neither a negotiation instrument nor a mere compliance tool. It is above all an evidentiary exercise, subject to stringent requirements: fairness in the collection of information, respect for the adversarial principle, impartiality of those conducting the investigation, traceability of methods, integrity of the material gathered.

The central question is not: Did the company cooperate? but rather: Are the facts established reliable, admissible, and legally usable? The French Model is an evidentiary model, grounded in the quality of factual work and the protection of fundamental rights.  It reflects a procedural culture in which the value of an investigation depends less on its efficiency than on the robustness, loyalty, and legal usability of the material produced.

This demanding evidentiary approach is reinforced by the case law of labour and criminal courts, as well as by the expectations of independent authorities such as the AFA, the CNIL, and the Defender of Rights. It is also consistent with the Proposal for a Law of 9 December 2025, which seeks to introduce a legal status for internal investigations and to consolidate this evidentiary orientation within a statutory framework.

By shaping internal investigations according to national procedural principles and evidentiary guarantees, France transforms an imported practice into a domesticated mechanism embedded within its own legal order. This evidentiary model forms the foundation upon which hybrid investigations develop, combining operational needs with the requirements of fairness and factual integrity.

IV. Technology as a Revealer of Investigative Cultures

Contemporary internal investigations rely heavily on standardized tools for data collection, processing, and document review, now used across most international groups. Yet the existence of common tools does not produce homogeneous practices. On the contrary, their use sharply exposes the differences between the American, European, and French approaches. The arrival of AI does not create a new model: it tests the three existing ones and brings their underlying logics to the surface.

4.1 United States: Technology in the Service of Efficiency and Negotiation

In the American Model, document review is conceived as an instrument of efficiency and resolution. Technology enables large‑scale collection, rapid analysis, the immediate production of a factual narrative usable in dialogue with the authorities. It fits within a logic of proactive cooperation and risk management.

4.2 Europe: Technology Constrained by Proportionality

In the European Model, the same tools are subject to strict requirements of proportionality, data minimization, traceability, justification of methodological choices. Technology becomes as much an object of procedural compliance as a means of analysis.

4.3 France: Technology Does Not Create Evidence

In the French Model, technology cannot replace the requirements of fairness, adversarial balance, and evidentiary rigor. The way in which data are collected, selected, contextualized, interpreted directly determines their admissibility and probative value. The tool does not create evidence; it reveals the quality — or the weaknesses — of the factual work. 

Technology thus acts as a silent revealer of the legal cultures and evidentiary requirements specific to each model.

V. Internal Investigations in the Age of AI: Towards a Silent Convergence of Models?

The emergence of artificial intelligence in internal investigations does not create a fourth model. It acts as a revealer of existing tensions and as a factor of convergence between the American, European, and French approaches. AI does not alter the underlying principles; it alters the scale, speed, and nature of factual work.

5.1 AI Amplifies the Strengths and Weaknesses of Each Model

In the United States, AI reinforces the logic of efficiency: accelerated analysis of massive volumes, automated pattern detection, and rapid production of factual narratives usable in negotiation. AI also heightens evidentiary risks. Under the Daubert standard, courts increasingly scrutinize the reliability, testability, error rates, and explainability of algorithmic outputs. The DOJ and SEC expect companies to document the methods used, preserve audit trails, and be able to explain how algorithmic tools contributed to factual findings. AI thus strengthens the negotiation logic while exposing the fragility of conclusions in follow‑on litigation.

In Europe, AI immediately encounters the requirements of proportionality, minimization, and justification. The AI Act reinforces this orientation: systems used in contexts affecting rights or producing factual material must ensure traceability, risk management, documentation of methodological choices, and control of bias. Organizations must now document not only what they do, but how the algorithm does it. AI becomes both a tool of analysis and an object of regulatory compliance.

In France, AI cannot circumvent fairness, adversarial balance, or evidentiary rigor. The admissibility of a fact produced or filtered by an algorithm depends on the loyalty of the collection, the integrity of the data, and the ability to explain the method used. The CNIL, AFA, and PNF already emphasize the need for traceability, transparency of methods, and preservation of evidentiary integrity. AI therefore reinforces the French evidentiary orientation: technology does not create evidence; it reveals the quality — or the weaknesses — of the factual work.

5.2 AI Creates a Common Need: Traceability

This is where the models converge. AI requires all systems to ensure enhanced traceability, a minimum level of explainability, justification of methodological choices, control of bias, a clear articulation between human and automated analysis. These are precisely the points where the three models, despite their differences, begin to align.

5.3 AI Recenters Internal Investigations on the Human Element

Paradoxically, the more AI advances, the more the value of an internal investigation depends on the ability to read behaviors, understanding organizational dynamics, interpreting weak signals, contextualizing facts, mastering adversarial balance. 

AI processes data; it does not read intentions, loyalties, or contextual effects. It does not replace human analysis — it makes it more necessary.

5.4 The Moment of Convergence

AI does not eliminate the differences between the American, European, and French approaches. But it creates a zone of functional convergence: the United States must strengthen traceability and evidentiary robustness. Europe must integrate more powerful tools without abandoning proportionality. France must articulate fairness, evidence, and advanced technologies.

AI forces the three models to converge around a shared imperative: producing facts that are reliable, traceable, and interpretable.

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Conclusion: Three Models, One Shared Demand for Factual Integrity

1. Comparing the American, European, and French models shows that an internal investigation is not a neutral exercise per se. It is shaped by legal cultures, institutional expectations, and differing conceptions of evidence, risk, and decision‑making. Reading these three models from within different legal environments — whether American, European, or French — makes it possible to understand how the same factual situation can generate profoundly different interpretations, expectations, and outcomes. In transnational settings, these divergences impact how facts are established, interpreted, and used. They condition the credibility of an investigation, the strength of a decision, and an organization’s ability to respond simultaneously to multiple authorities. Viewing these three models from Paris, Brussels, or New York reveals what is truly at stake in internal investigations: the tension between efficiency and fairness, between cooperation and protection, between speed and evidentiary rigor, between massive documentation and factual integrity.

This triple vantage point offers a unique perspective: one that makes it possible to understand American expectations without losing sight of French requirements, and to articulate European constraints with North American transactional logics. Above all, it makes visible the cultural, legal, and behavioral friction zones that run through investigations conducted within international groups. The Proposal for a Law of 9 December 2025 reinforces this dynamic by seeking to introduce a legal status for internal investigations and to consolidate the French evidentiary orientation within a statutory framework.

2. The emergence of artificial intelligence intensifies these tensions. It highlights what distinguishes the models, but also what brings them closer: the need to produce facts that are reliable, traceable, and interpretable. In the United States, AI confronts evidentiary scrutiny under the Daubert standard and the expectations of the DOJ and SEC regarding documentation and reliability. In Europe, AI is constrained by the requirements of the AI Act, which imposes traceability, explainability, and risk management. In France, AI cannot circumvent fairness, adversarial balance, or evidentiary rigor, and must comply with the expectations of the CNIL, AFA, and PNF regarding loyalty, integrity, and methodological transparency. AI forces organizations to reconcile efficiency, proportionality, and fairness, and to rethink the respective roles of human and automated analysis.

3. In a world where organizations operate under multiple simultaneous jurisdictions, the ability to read facts through these three models, anticipate their effects, and secure decision‑making in this in‑between space becomes a central element of real governance. It is precisely in this technical, legal, and human space that the value of an internal investigation is now constructed. Factual integrity thus becomes the meeting point — and sometimes the point of tension — between the three models.

4. Towards Trans‑Jurisdictional Competence: Why Internal Investigations Require Hybrid Teams

The analysis of the American, European, and French Models reveals an operational reality that is too often underestimated: no single model is sufficient to meet the demands of contemporary internal investigations. Each system brings a specific strength:

• The United States excels in efficiency, risk management, and the ability to produce a usable factual narrative quickly.
• Europe guarantees proportionality, methodological documentation, and the protection of fundamental rights.
• France contributes a unique evidentiary discipline, grounded in fairness, adversarial balance, and the admissibility of facts.

Taken together, these three models do not oppose one another — they complement each other.

In international groups, the most robust internal investigations are those conducted by professionals who embody these three legal cultures: capable of anticipating the DOJ and SEC expectations, meeting European requirements of proportionality and documentation, and securing the evidentiary value of facts under French standards.

This hybridization is not an intellectual luxury. It is an operational necessity. It prevents the blind spots inherent in each model, mitigates the risk of simultaneous non‑compliance, produces facts that are usable across jurisdictions, strengthens the credibility of the investigation before authorities, and — above all — ensures factual integrity that withstands pressure, bias, and interpretation.

The most effective internal investigations are those that combine American efficiency, European proportionality, and French evidentiary rigor. In a world where companies operate under multiple legal sovereignties, this trans‑jurisdictional competence becomes a major strategic advantage. It transforms the internal investigation into a genuine tool of governance, capable of producing facts that are robust, interpretable, and legitimate — everywhere.

These observations and analyses do not claim to encompass all existing models. They focus on the American, European, and French approaches as primary frameworks, without excluding the contributions that other national legal systems could offer in future research.

Main Sources

U.S. Model

• Department of Justice & Securities and Exchange Commission, A Resource Guide to the U.S. Foreign Corrupt Practices Act, 2nd ed., 2020. https://www.justice.gov/criminal-fraud/file/1292051/download
• U.S. Department of Justice, Justice Manual, § 9‑28.000 – Principles of Federal Prosecution of Business Organizations. https://www.justice.gov/jm/jm-9-28000-principles-federal-prosecution-business-organizations
• U.S. Department of Justice, Antitrust Division, Leniency Program and Policies. https://www.justice.gov/atr/leniency-program
• U.S. Federal Rules of Evidence, Rule 702 (Daubert Standard) — admissibility of expert and scientific evidence. https://www.law.cornell.edu/rules/fre/rule_702
• U.S. Courts, case law on algorithmic evidence and reliability (Daubert line of cases)

European Model

• Regulation (EU) 2016/679 (GDPR). https://eur-lex.europa.eu/eli/reg/2016/679/oj
•  Directive (EU) 2019/1937 on the protection of whistleblowers. https://eur-lex.europa.eu/eli/dir/2019/1937/oj
• Directive (EU) 2015/849 (AML/CFT). https://eur-lex.europa.eu/eli/dir/2015/849/oj
• Regulation (EU) 2024/… (AI Act) — requirements of traceability, explainability, risk management for high‑risk AI systems. https://eur-lex.europa.eu
• European Data Protection Board (EDPB) — guidelines on data processing, proportionality, and investigations.
• European Commission, Guidance on internal investigations in digital regulation contexts (DSA, DMA).

French Model

• Law No. 2016‑1691 of 9 December 2016 (“Sapin II”). https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000033558528
• French Anti‑Corruption Agency (AFA), Recommendations (2017). https://www.agence-francaise-anticorruption.gouv.fr/fr/recommandations-2017
• French Anti‑Corruption Agency (AFA), Recommendations (2021). https://www.agence-francaise-anticorruption.gouv.fr/fr/recommandations-2021
• CNIL, guidelines and decisions on data processing in internal investigations. https://www.cnil.fr
• Parliamentary work on the legislative framework for internal investigations (2023–2025) — including the Proposition de loi n° 2208 du 9 décembre 2025. https://www.assemblee-nationale.fr https://www.senat.fr
• PNF, guidance on cooperation, evidence, and internal investigations (CJIP practice).
• French case law (Cour de cassation, administrative authorities) on loyalty, adversarial balance, and admissibility of evidence.

Technology and AI

• European Commission, AI Act (2024). https://eur-lex.europa.eu
• OECD, Principles on Artificial Intelligence (2019). https://oecd.ai/en/ai-principles
• EDPB, guidance on AI, automated decision‑making, and data processing.
• CNIL, guidance on AI systems, explainability, and algorithmic traceability.
• U.S. Courts, case law on algorithmic evidence and reliability (Daubert).
• U.S. NIST, AI Risk Management Framework (2023).