Société Générale S.A. OFAC Settlement: $53.97M (2018)

For at least five years up to and including 2012, Société Générale S.A. processed transactions to or through the United States or U.S. financial institutions that involved countries or persons subject to the sanctions programs administered by OFAC. Société Générale S.A. often processed these transactions in a non-transparent manner that removed, omitted, obscured, or otherwise failed to include references to OFAC-sanctioned parties in the information sent to the U.S. financial institutions involved in the transactions.

The 1,077 apparent violations encompassed three sanctions programs. Société Générale S.A. processed 796 transactions involving Cuba totaling approximately $5,503,813,992.25 between July 11, 2007 and October 26, 2010, in apparent violation of the CACR. Société Générale S.A. processed 30 transactions involving Iran totaling approximately $34,152,962.50 between November 20, 2008 and January 20, 2009, in apparent violation of the ITSR. Société Générale S.A. processed 251 transactions involving Sudan totaling $22,486,039.61 between July 9, 2007 and March 19, 2012, in apparent violation of the SSR.

The conduct occurred across multiple bank units and business lines and apparently continued practices set out in stripping instructions that the bank drafted, disseminated, and revoked prior to 2007. Numerous Société Générale S.A. employees and members of bank management across multiple business lines and bank locations had actual knowledge of the conduct.

OFAC determined that Société Générale S.A. voluntarily self-disclosed the Apparent Violations and that the Apparent Violations constitute an egregious case. The total base penalty amount for all Apparent Violations was $101,630,490.80, comprising a base penalty of $25,870,000.00 for the Cuba-related apparent violations under the CACR, $34,152,962.50 for the Iran-related apparent violations under the ITSR, and $41,656,278.22 for the Sudan-related apparent violations under the SSR. The settlement amount of $53,966,916.05 reflects OFAC's consideration of the facts and circumstances pursuant to the General Factors Affecting Administrative Action under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. Part 501, app. A. This OFAC settlement is part of a global settlement among Société Générale S.A., OFAC, the Board of Governors of the Federal Reserve System, the U.S. Department of Justice, the New York County District Attorney's Office, the U.S. Attorney for the Southern District of New York, and the New York State Department of Financial Services.

Processing transactions to or through U.S. financial institutions by removing, omitting, or obscuring references to OFAC-sanctioned parties in payment instructions — even after formal stripping instructions are revoked — creates apparent violations across multiple programs. Rejections of payment instructions by U.S. correspondent banks, and bank employee discussions noting similarities between internal payment practices and published OFAC enforcement actions, were identified as warning signs that were ignored. Actual knowledge of non-compliant conduct among numerous employees and bank management without corrective action was treated as a significant aggravating factor.

In response, Société Générale S.A. established a centralized sanctions compliance function, implemented group-level and business-line-level enhancements, increased compliance staffing and budget, and deployed a comprehensive training regime including targeted, in-person training for employees with higher risk of exposure to sanctions-related transactions.

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