Question juridique clé
Whether the criminal prosecution for fraud acts committed before 1997-08-29 was time-barred
Solution extraite
Yes; the acts committed before 29 August 1997 were already time-barred when the appellate judgment was issued on 29 August 2012.
Motifs extraits
Under the applicable former limitation rules, prosecution for qualified fraud prescribed after 15 years; the limitation period starts on the day of the criminal act and ends with the pronouncement of the conviction. Thus, earlier acts were time-barred, while possible delays in the complex proceedings were irrelevant.