In the case of Total S.A. and Vitol S.A. v. France, the Court held that there had been no violation of the no punishment without law.

The case concerned the applicant companies’ conviction for the offence of bribing foreign public officials.

The applicant companies were found guilty of bribing foreign public officials, in contravention of the UN “oil-for-food” programme, and sentenced under Article 435-3 of the Criminal Code. Relying on Article 7 of the Convention (no punishment without law), they complained that the law in question lacked accessibility and foreseeability.

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