What did Societe Generale do wrong?

Processed transactions involving Cuba, Iran, Sudan, and other sanctioned jurisdictions between 2004-2010. Used non-transparent payment practices including omitting sanctioned party names from SWIFT messages.

How much did Societe Generale pay?

Over $1.3 billion across OFAC, DOJ, NYDFS, and other regulators in 2018. The OFAC portion was $53.9 million.

Did Societe Generale cooperate?

Yes. The bank cooperated with investigations and implemented remedial measures, which contributed to penalty mitigation.

What is the compliance lesson?

Payment transparency is non-negotiable. Omitting or altering sanctioned party information from payment messages is a direct violation. Retroactive compliance is expensive.

Societe Generale OFAC case study

In 2018, Societe Generale agreed to pay over $1.3 billion in combined penalties for sanctions violations involving Cuba, Iran, and other sanctioned jurisdictions processed through the US financial system.

What happened

Between 2004 and 2010, Societe Generale processed billions of dollars in transactions involving parties in Cuba, Iran, Sudan, and other sanctioned jurisdictions. The bank used non-transparent payment practices, including omitting sanctioned party names from SWIFT messages.

Penalty

The 2018 settlement involved OFAC ($53.9M portion), DOJ, NYDFS, and other regulators. The total across all agencies exceeded $1.3 billion. The bank cooperated and implemented remedial measures.

Key lessons

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Frequently Asked Questions

What did Societe Generale do wrong?: Processed transactions involving Cuba, Iran, Sudan, and other sanctioned jurisdictions between 2004-2010. Used non-transparent payment practices including omitting sanctioned party names from SWIFT messages.
How much did Societe Generale pay?: Over $1.3 billion across OFAC, DOJ, NYDFS, and other regulators in 2018. The OFAC portion was $53.9 million.
Did Societe Generale cooperate?: Yes. The bank cooperated with investigations and implemented remedial measures, which contributed to penalty mitigation.
What is the compliance lesson?: Payment transparency is non-negotiable. Omitting or altering sanctioned party information from payment messages is a direct violation. Retroactive compliance is expensive.