The FCPA world was rocked last week with two enforcement actions involving illegal conduct by two separate entities and representatives of the Libyan government in regard to its sovereign wealth fund. One involved the investment adviser Legg Mason and the second involved the French banking giant Société Générale S.A. (SocGen), a global financial services institution based in Paris, France, and its wholly owned subsidiary, SGA Société Générale Acceptance N.V. SocGen paid a criminal fine of $585 million for its FCPA violations—one-half payable to the United States and one-half payable to French Parquet National Financier (PNF) in Paris relating to the Libya corruption scheme.
