Did the DOJ Give SocGen an Unofficial Discount?

The FCPA Blog

09.18.2018

In this article, Daniel Patrick Wendt discusses the settlement between Societe Generale SA (SocGen) and the U.S. Department of Justice (DOJ) over Libya-related FCPA and LIBOR-related allegations. Wendt describes the process of calculating the criminal fine range in the Deferred Prosecution Agreement (DPA) using the Sentencing Guidelines and possible explanations on why SocGen may have effectively received an unofficial reduction on their fine from the DOJ. "After reviewing the papers, however, I suspect instead that the DOJ agreed that the conduct at issue was limited to a specific unit within SocGen, which would justify the lower culpability score for the FCPA fine," Wendt said.