Jenner & Block

Lessons Learned from Société Générale and Legg Mason FCPA Resolution

On June 4, the US Department of Justice (DOJ) announced two Foreign Corrupt Practices Act (FCPA) resolutions with financial institutions arising out of a multi-year bribery scheme involving bribes to Libyan officials.  First, the Paris-based Société Générale entered into a deferred prosecution agreement with DOJ and simultaneously entered into a criminal settlement agreement with the French prosecutor, Parquet National Financier (PNF).  Société Générale’s resolution with DOJ included a $585 million criminal penalty, which US authorities said would be offset by the $293 million fine the bank agreed to pay the PNF.  Second, the US investment management firm Legg Mason entered into a non-prosecution agreement for related conduct, agreeing to pay a total of $64.2 million to resolve the matter. 

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