General
Sometimes it takes a large enforcement action to underscore basic and important anti-corruption compliance principles. The Société Générale enforcement action demonstrated two important principles – the dangers of a weak corporate culture and the need to apply basic third-party risk management practices to respond to and resolve red flags
General
Société Générale and Legg Mason carried out a massive bribery scheme to pay Gaddafi-era government officials in Libya in exchange for large investments by Libya government funds. In total, Société Générale and Legg Mason paid over $90 million in bribes in exchange for over $3.6 billion in investments
General
In a one-two punch of FCPA enforcement actions, the Justice Department announced two related FCPA settlements involving Société Générale and Legg Mason for Gaddafi-era bribery payments to Libyan officials. In the first settlement announced, Société Générale agreed to pay a total of $860 million in criminal penalties, $585