"Compliance must be integrated into corporate strategy to manage international trade risks" asserts Emmanuel Dupic, Ethics and Compliance Director of the Dassault Aviation Group

Following the recent seminar "How is Geopolitics Transforming the Compliance Function?" hosted by the ESSEC Alumni Law Club, in partnership with the ESSEC Institute for Geopolitics & Business, we sat down with Emmanuel Dupic, Ethics and Compliance Director of the Dassault Aviation Group and former French Prosecutor. In this conversation, Dupic explores how compliance has evolved from a mere regulatory shield into a strategic "watchtower" essential for navigating today’s fragmented global landscape. By deconstructing the shift from simple export control to sophisticated risk mapping, he illustrates why the modern Chief Compliance Officer is now a central architect of corporate resilience, securing business viability amidst the "minefield" of international sanctions and extraterritoriality.

1 - The defense and aerospace industry is inherently exposed to international power struggles. How has compliance at Dassault Aviation become a central tool for managing geopolitical risk, going far beyond strict adherence to export rules?

Emmanuel DUPIC - Subject to major non-compliance risks, international companies define compliance programs based primarily on a detailed risk assessment through the company's risk mapping.

This process is part of a risk-based approach requiring the company to understand and evaluate the corruption risks to which it is actually exposed before taking measures and procedures to control them effectively. The methodology consists of six steps, including identifying, evaluating, and prioritizing risks; implementing an action plan to ensure control; and regular updating and archiving. This exercise applies to all companies within the corporate group.

Geopolitical risk encompasses standards relating to corruption and money laundering, as well as compliance with sanctions and embargoes.

2 - International sanctions have become precision weapons in the foreign policy arsenal. How does the compliance department navigate this "minefield" for a group like Dassault Aviation?

E.D. - In terms of export control, a reinforced evaluation of customers is required (due diligence) with a systematic verification of the parties (SDN lists, country lists) and sectors (energy, defense, metallurgy, mining, high-tech) involved.

Companies conduct a detailed analysis of the value chain: final destination, end-users, transit countries, and the presence of high-risk banks or intermediaries (notably in identified re-export hubs). They identify products subject to EAR or ITAR standards, verify items covered by Russia/Belarus sectoral sanctions, and implement automatic blocking mechanisms.

3 - Defense contracts span decades. How do you build a robust compliance framework capable of withstanding unpredictable shifts in geopolitical alliances?

E.D. - The implementation of a compliance program is a sustainable process that unfolds over time. Compliance involves a long-term commitment from the company and its stakeholders, consistent with the production timelines of military industries. Furthermore, contracting with public entities requires an exemplary ethical and anti-corruption program, given the supplementary penalties (termination of public contracts) provided for companies convicted of corruption.

4 - In an economic sector where sovereignty is a major political issue, how does compliance contribute to ensuring the viability of the business model for a company that must navigate between extraterritorial norms and targeted coercive actions?

E.D. - The current geopolitical context reflects the end of free trade with the implementation of barriers such as embargoes and sanctions. Export control has become a major compliance risk for companies and poses a criminal risk regarding the circumvention of sanctions, which have multiplied since the war in Ukraine. Compliance aims to secure the company's actions within the context of the extraterritoriality of regulations.

5 - At a time when compliance integrates cybersecurity, sensitive data, business ethics, and geopolitical monitoring, how is the compliance function evolving?

E.D. - Given the compliance and ethical stakes for businesses, compliance must be integrated into the company's strategy to enable the management of risks associated with international trade. Compliance officers are thus becoming major players within companies, acting simultaneously as risk managers and guarantors of regulatory compliance.

ABOUT THE ESSEC INSTITUTE FOR GEOPOLITICS & BUSINESS

Created in 2024 by ESSEC, the Institute for Geopolitics & Business examines how geopolitical shocks reshape companies’ economic models.

Operating across ESSEC Business School’s campuses in France, Morocco, and Singapore, it brings a tri-continental perspective to what drives corporate competitiveness in the post-globalization era: vigilance, resilience, independence.

It feeds into ESSEC’s degree programs, executive education, and research to foster a new generation of geopolitics-proof business leaders capable of steering and growing companies amid an increasingly brutalized world.

Rooted in ESSEC’s academic excellence, the Institute draws on 4 flagship centers:

• the IRENE Center for Negotiation & Mediation,
• the Center for Geopolitics, Defense & Leadership,
• the Center for European Law & Economics, and
• the Chair Business & Industry in Africa.

Contact: Thomas FRIANG, Executive Director of the ESSEC Institute for Geopolitics & Business - friang@essec.edu