Societe Generale Archives - FCPA Professor

FCPA Flash Podcast – A Conversation With Kevin Abikoff Regarding FCPA Compliance Challenges And Other Developments

By Mike Koehler on December 11, 2018 in Compliance, DOJ FCPA Corporate Enforcement Policy, FCPA Flash, Foreign Law Enforcement Cooperation, Societe Generale

The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Kevin Abikoff (Co-chair of Hughes Hubbard & Reed’s Anti-Corruption and Internal Investigations Practice Group). In the podcast, Abikoff discusses: FCPA compliance challenges; his top two legal or policy developments in 2018 in the FCPA space; and whether the FCPA has truly been successful in achieving its objectives.

A Focus On The French Portion Of The Société Générale Enforcement Action

By Mike Koehler on June 26, 2018 in Guest Posts, Societe Generale

Previous posts here, here and here highlighted the U.S. prong of the recent Foreign Corrupt Practices Act enforcement action against French bank Société Générale S.A. (SoGen) “relating to a multi-year scheme to pay bribes to officials in Libya.”

In this guest post Cécile Terret & David Père (Paris-based attorneys with Bryan Cave Leighton Paisner) discuss the French portion of the global enforcement action.

Once Again The DOJ Shoots Itself In The Foot

By Mike Koehler on June 11, 2018 in DOJ, DOJ FCPA Corporate Enforcement Policy, Enforcement Agency Policy, Societe Generale, Voluntary Disclosure

This is the fourth time this general post has appeared on these pages (see here, here and here for prior posts).

So here it goes again.

The Department of Justice has long wanted companies to voluntarily disclose conduct that implicates the Foreign Corrupt Practices Act. Why then does the DOJ continually make decisions that should result in any board member, audit committee member, or general counsel informed of current event not making the decision to voluntarily disclose?

The recent Societe Generale enforcement action (see here and here for prior posts) is just the latest example.

DOJ “Piles On” Société Générale And Other Issues To Consider

By Mike Koehler on June 8, 2018 in DOJ “Piling On” Policy, Gray Cloud, Societe Generale

As highlighted in this prior post, in May the DOJ announced a non-binding policy discouraging “piling on” by instructing DOJ “components to appropriately coordinate with one another and with other enforcement agencies in imposing multiple penalties on a company in relation to investigations of the same misconduct.”

This prior post discussed how discouraging “piling on” sounds great, but it all depends on what “piling on” means.

Specifically, one area in which the DOJ’s policy is FCPA relevant is due to the transnational nature of alleged FCPA violations against foreign companies which may be subject to U.S. law enforcement and foreign law enforcement as well.

Societe Generale Resolves Net $293 Million FCPA Enforcement Action Concerning Conduct In Libya That Occurred 9-14 Years Ago

By Mike Koehler on June 4, 2018 in 2018 Enforcement Actions, DOJ Enforcement Action, Financial Services Industry, Foreign Non-Issuer Company, Libya, Societe Generale

Earlier today, the DOJ announced that “Société Générale S.A. (SoGen), a global financial services institution based in Paris, France, and its wholly owned subsidiary, SGA Société Générale Acceptance N.V. (“SGA”) agreed to resolve a Foreign Corrupt Practices Act enforcement action “relating to a multi-year scheme to pay bribes to officials in Libya.” As indicated in the DOJ release and confirmed by a DOJ representative, the net FCPA settlement amount is $293 million after crediting $293 million for a related French law enforcement action.

In addition, the DOJ announced that Société Générale agreed to pay $275 million for violations arising from its manipulation of the London InterBank Offered Rate (LIBOR).

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FCPA Flash Podcast – A Conversation With Kevin Abikoff Regarding FCPA Compliance Challenges And Other Developments

A Focus On The French Portion Of The Société Générale Enforcement Action

Once Again The DOJ Shoots Itself In The Foot

DOJ “Piles On” Société Générale And Other Issues To Consider

Societe Generale Resolves Net $293 Million FCPA Enforcement Action Concerning Conduct In Libya That Occurred 9-14 Years Ago

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