This article by Ama Adams, Brendan Hanifin, and Emerson
Siegle was published by Law360 on November 30, 2018.
On November 19, 2018, Société
Générale S.A. ("Société
Générale"), a Paris-based financial institution,
announced that it will pay $1.34 billion, pursuant to coordinated
settlements with the U.S. Treasury Department's Office of
Foreign Assets Control ("OFAC") and other U.S.
regulators, to resolve the bank's liability for 1,077 apparent
violations of U.S. sanctions targeting Cuba, Iran, and
Sudan.1 The portion of the settlement allocated to OFAC,
$53,996,916.05, represents the largest OFAC enforcement action in
2018, and the $1.34 billion total penalty is the second largest
sanctions-related settlement in U.S. history.2
