June 12, 2018

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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