Specifically, Société Générale agreed to remit to the U.S. government $53,966,916.05 to settle its potential civil liability for 1,077 violations of the Cuban Assets Control Regulations, Iranian Transactions and Sanctions Regulations, and Sudanese Sanctions Regulations.
The total base penalty for the alleged violations that occurred between 2007 and 2012 was $101,630,490.80.
OFAC said Société Générale “exercised a reckless disregard for U.S. sanctions requirements when it demonstrated a pattern or practice across multiple bank units and business lines of processing transactions to or through U.S. financial institutions after removing, omitting, obscuring or otherwise failing to include the involvement of OFAC-sanctioned parties in associated payment instructions.”
OFAC credited the bank for self-disclosing the violations to the agency and cooperating with investigators.
In addition, Société Générale has centralized its sanctions compliance functions, expanded its compliance staff and instituted company-wide sanctions training, OFAC said.
OFAC said Société Générale has not received a penalty notice or finding of violation from the agency in the past five years.