Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Haussmann 1864 Capital Management LLC
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Haussmann 1864 Capital Management LLC.
Reported ownership and control details
Form ADV · Filing date 2026-03-31 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | SG AMERICAS SECURITIES HOLDINGS, LLCMEMBERDomestic entity | HAUSSMANN 1864 CAPITAL MANAGEMENT LLC | 75% or moreCode E | Yes | MEMBER05/2024 | Schedule APDF page 25 |
| 2 | Joseph FalconeCHIEF EXECUTIVE OFFICERIndividual | HAUSSMANN 1864 CAPITAL MANAGEMENT LLC | Less than 5%Code NA | Yes | CHIEF EXECUTIVE OFFICER07/2024 | Schedule APDF page 25 |
| 3 | CHRISTOPHER WILLIAM RUFFINOCHIEF FINANCIAL OFFICERIndividual | HAUSSMANN 1864 CAPITAL MANAGEMENT LLC | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER05/2024 | Schedule APDF page 25 |
| 4 | Marc Michel CacchioliCHIEF OPERATING OFFICERIndividual | HAUSSMANN 1864 CAPITAL MANAGEMENT LLC | Less than 5%Code NA | Yes | CHIEF OPERATING OFFICER09/2024 | Schedule APDF page 25 |
| 5 | George TalaricoCHIEF COMPLIANCE OFFICERIndividual | HAUSSMANN 1864 CAPITAL MANAGEMENT LLC | Less than 5%Code NA | No | CHIEF COMPLIANCE OFFICER07/2025 | Schedule APDF page 25 |
| 6 | JEAN-YVES FILLIONDIRECTORIndividual | HAUSSMANN 1864 CAPITAL MANAGEMENT LLC | Less than 5%Code NA | Yes | DIRECTOR02/2026 | Schedule APDF page 25 |
| 7 | GREGORY WAYNE MACCORDYDIRECTORIndividual | HAUSSMANN 1864 CAPITAL MANAGEMENT LLC | Less than 5%Code NA | Yes | DIRECTOR02/2026 | Schedule APDF page 25 |
| 8 | SOCIÉTÉ GÉNÉRALEMEMBERForeign entity | SG AMERICAS SECURITIES HOLDINGS, LLC | 75% or moreCode E | Yes | MEMBER05/2024 | Schedule BPDF page 25 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 3/31/2026 4:14:59 PM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies1 Yes1 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?Yes
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions2 Yes3 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 34 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
criminal · block 1PDF pages 26–27
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship.
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number).
U.S. DEPARTMENT OF JUSTICE, SPECIFICALLY, THE U.S. ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT OF NEW YORK ("DOJ").
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY):
11/19/2018
Exact
Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related).
ONE FELONY COUNT OF CONSPIRACY TO VIOLATE THE TRADING WITH THE ENEMY ACT ("TWEA"), TITLE 50, UNITED STATES CODE, SECTIONS
4303. 4305, AND 4315(A), AND THE CUBAN ASSETS CONTROL REGULATIONS, TITLE 31, CODE OF FEDERAL REGULATIONS, SECTION 515.201,
PROMULGATED THEREUNDER, IN CONNECTION WITH PROCESSING US DOLLAR PAYMENTS BETWEEN, BY, THROUGH, AND TO ANY BANKING
INSTITUTION, WITH RESPECT TO ANY PROPERTY SUBJECT TO THE JURISDICTION OF THE UNITED STATES, IN WHICH CUBA HAS ANY INTEREST OF
ANY NATURE WHATSOEVER, DIRECT OR INDIRECT, AND THE EVASION AND AVOIDANCE OF THE AFOREMENTIONED PROHIBITION. SOCIÉTÉ
GÉNÉRALE S.A. ("SOCIÉTÉ GÉNÉRALE") ENTERED PLEA OF NOT GUILTY, WHICH IS SUBJECT TO A DEFERRED PROSECUTION AGREEMENT BETWEEN
SOCIÉTÉ GÉNÉRALE AND THE UNITED STATES DEPARTMENT OF JUSTICE.
C.
Did any of the Charge(s) within the Event involve a felony?
Yes
No
D.
Current status of the Event?
Pending
On Appeal
Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY):
11/30/2021
Exact
Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail:
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid.
ON NOVEMBER 19, 2018 SOCIÉTÉ GÉNÉRALE S.A. ("SG") ENTERED INTO A DEFERRED PROSECUTION AGREEMENT ("DPA") WITH THE US DEPARTMENT
OF JUSTICE, SPECIFICALLY, THE U.S. ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT OF NEW YORK ("DOJ"), PURSUANT TO WHICH SG CONSENTED
TO THE FILING OF A ONE-COUNT INFORMATION IN THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, CHARGING SG WITH
CONSPIRING TO VIOLATE THE TRADING WITH THE ENEMY ACT, 31 U.S.C. §§ 4303, 4305, 4315(A) AND THE CUBAN ASSETS CONTROL REGULATIONS, 31
C.F.R. § 515.201, FOR SG'S ROLE IN PROCESSING CERTAIN U.S. DOLLAR TRANSACTIONS USING THE U.S. FINANCIAL SYSTEM IN CONNECTION WITH
CREDIT FACILITIES INVOLVING CUBA. UNDER THE TERMS OF THE DPA, SG (1) AGREED TO PAY $717,200,000; (2) STIPULATED AS TO A STATEMENT OF
FACTS DESCRIBING THE CONDUCT AT ISSUE; AND (3) AGREED TO ABIDE BY CERTAIN OTHER REQUIREMENTS, INCLUDING OBLIGATIONS TO COOPERATE
WITH THE DOJ, TO COMMIT NO FUTURE CRIMES UNDER FEDERAL LAWS OF THE UNITED STATES, TO ABIDE BY THE TERMS OF THE OTHER RELATED
SETTLEMENTS AGREEMENTS ENTERED INTO BY SG ON THE SAME DAY WITH OTHER FEDERAL AND STATE AUTHORITIES AND OTHER EQUIVALENT ORDERS
ISSUED BY SG'S U.S. FEDERAL OR STATE REGULATORS RELATING TO SG'S SANCTIONS OR BAN. PURSUANT TO THE DPA, THE CHARGES HAVE BEEN
DROPPED.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.)
THE CHARGED CONDUCT TOOK PLACE FROM AT LEAST 2004 UP THROUGH AND INCLUDING 2012 AND INVOLVED SG'S STRUCTURING, CONDUCTING AND
CONCEALING USD PAYMENTS VIA FINANCIAL INSTITUTIONS LOCATED IN THE COUNTY OF NEW YORK. AMONG OTHER THINGS SG MADE INACCURATE OR
INCOMPLETE NOTATIONS IN WIRE TRANSFER RECORDS THAT RESULTED IN MORE THAN 2,500 SANCTIONS VIOLATING TRANSACTIONS VALUED AT
CLOSE TO $13 BILLION DURING THIS PERIOD.criminal · block 2PDF pages 27–29
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship.
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number).
UNITED STATES DISTRICT COURT - EASTERN DISTRICT OF NEW YORK. 18 CR 253.
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY):
06/05/2018
Exact
Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related).
TWO FELONY COUNTS OF CONSPIRACY TO COMMIT OFFENSES AGAINST THE UNITED STATES, IN VIOLATION OF TITLE 18, UNITED STATES CODE,
SECTION 317 (FIRST COUNT, TO VIOLATE THE ANTI-BRIBERY PROVISIONS OF THE FOREIGN CORRUPT PRACTICES ACT OF 1977, AS AMENDED,
TITLE 15, U.S. CODE, SECTION 78DD-3; SECOND COUNT, TO DELIVER OR CAUSE TO BE DELIVERED FALSE, MISLEADING, OR KNOWINGLY
INACCURATE REPORTS CONCERNING MARKET INFORMATION THAT TEND TO AFFECT THE PRICE OF A COMMODITY IN INTERSTATE COMMERCE, IN
VIOLATION OF TITLE 7, UNITED STATES CODE, SECTION 13(A)(2). SOCIÉTÉ GÉNÉRALE S.A. ("SOCIÉTÉ GÉNÉRALE") ENTERED PLEA OF NOT GUILTY
ON BOTH COUNTS, WHICH ARE SUBJECT TO A DEFERRED PROSECUTION AGREEMENT BETWEEN SOCIÉTÉ GÉNÉRALE AND THE UNITED STATES
DEPARTMENT OF JUSTICE.
C.
Did any of the Charge(s) within the Event involve a felony?
Yes
No
D.
Current status of the Event?
Pending
On Appeal
Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY):
12/02/2021
Exact
Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail:
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid.
SG ENTERED INTO A DEFERRED PROSECUTION AGREEMENT WITH THE CRIMINAL DIVISION OF THE U.S. DEPARTMENT OF JUSTICE AND THE U.S.
ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NEW YORK IN WHICH SG ACCEPTED RESPONSIBILITY FOR CONSPIRACY TO COMMIT OFFENSES
AGAINST THE U.S., IN VIOLATION OF TITLE 18, U.S.C. SEC. 371, AS DESCRIBED IN THE DPA'S STATEMENT OF FACTS. THE DOJ, UNDER THE TERMS OF
THE DPA AGREED TO DEFER PROSECUTION OF SG. THE TERM OF THE DPA IS 3 YEARS. SG, UNDER THE DPA, AGREED ON BEHALF OF ITSELF AND ITS
SUBSIDIARIES, TO CERTAIN NOTICE, DISCLOSURE, AND COOPERATION REQUIREMENTS. FURTHER, SG AGREED TO A MONETARY PENALTY OF
$860,552,888, CONSISTING OF A MONETARY PENALTY FOR THE FCPA VIOLATIONS IN THE AMOUNT OF $585,552,888, AGAINST WHICH SG RECEIVED
CREDIT FOR A $500,000 CRIMINAL MONETARY PENALTY AGREED TO BY SG'S SUBSIDIARY, SGA SOCIÉTÉ GÉNÉRALE ACCEPTANCE, N.V. UNDER A PLEA
AGREEMENT WITH THE DOJ AND A $292,776,444 PAYMENT MADE BY SG AS PART OF A CRIMINAL RESOLUTION WITH THE PARQUET NATIONAL
FINANCIER CONCERNING CONDUCT RELATED TO THE FCPA VIOLATIONS AND A MONETARY PENALTY OF THE LIBOR VIOLATIONS, IN THE AMOUNT OF
$275,000,000. THE DOJ PAYMENTS WERE WIRED ON JUNE 15, 2018. PURSUANT TO THE DPA, THE CHARGES HAVE BEEN DROPPED.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.)
THE 1ST COUNT RELATED TO THE CONDUCT OF CERTAIN EMPLOYEES OF SG WHO, BY AT LEAST 2006, KNEW THAT AN INTERMEDIARY USED FOR
CERTAIN TRANSACTION WITH LIBYAN STATE-OWNED AND CONTROLLED INSTITUTIONS PAID BRIBES AND PROVIDED OTHER IMPROPER FINANCIAL
BENEFITS TO LIBYAN GOVERNMENT OFFICIALS IN ORDER TO SECURE FINANCIAL INVESTMENTS FOR SG, AND AGREED TO CONTINUE TO USE THE
INTERMEDIARY DESPITE THAT KNOWLEDGE ("THE FCPA VIOLATIONS"). THE 2ND COUNT RELATED TO THE CONDUCT OF CERTAIN EMPLOYEES OF SG
WHO BETWEEN MAY 2010 AND AT LEAST OCTOBER 2011, PROMULGATED FALSE AND MISLEADING USD LIBOR SUBMISSIONS AND IN 2006,
PROMULGATED FALSE AND MISLEADING JAPAN YEN LIBOR SUBMISSIONS, BOTH IN VIOLATION OF TITLE 7, USC, SEC. 13(A)(2) (TOGETHER THE "LIBOR
VIOLATIONS").regulatory · block 1SOCIÉTÉ GÉNÉRALE S.A.PDF pages 29–31
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- COMMODITY FUTURES TRADING COMMISSION
- Monetary/Fine Amount — filed text
- $ 1,500,000.00
- How was matter resolved — filed text
- Decision & Order of Offer of Settlement
Action status / disposition — filed text
SG WAS FINED $1,500,000, ORDERED TO CEASE AND DESIST FROM VIOLATIONS OF RELEVANT SECTIONS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, AND REQUIRED TO PERFORM CERTAIN REMEDIAL UNDERTAKINGS INCLUDING PROVIDING BACK-REPORTED CORRECTED HISTORICAL VALUATIONS FOR LIVE SWAPS AFFECTED BY CALCULATION ISSUES TO THE SDR AND TO CLIENTS (UPON REQUEST), AS WELL AS SUBMITTING REMEDIAL REPORTS AT 120 DAYS AND 365 DAYS FOLLOWING THE ORDER.
Other filed details
Description of allegations — filed text
THE CFTC ALLEGED THAT FROM APPROXIMATELY 2013 TO JULY 2021, SOCIÉTÉ GÉNÉRALE (SG), AS A SWAP DEALER, FAILED TO DILIGENTLY SUPERVISE ITS PROCESS FOR DISCLOSING CFTC-REQUIRED MID-MARKET MARKS TO ELIGIBLE COUNTERPARTIES AND REPORTING VALUATIONS TO A SWAP DATA REPOSITORY (SDR). SPECIFICALLY, FOR MANY YEARS, SG FAILED TO DISCLOSE DAILY MID-MARKET MARKS ENTIRELY TO A SIGNIFICANT PORTION OF ELIGIBLE COUNTERPARTIES. FOR CERTAIN OTHER SWAPS, SG PROVIDED COUNTERPARTIES INACCURATE SWAP VALUATION DATA TO AN SDR. FINALLY, SG FAILED TO DISCLOSE PRE-TRADE MID-MARKET MARKS TO COUNTERPARTIES OVER CERTAIN ELECTRONIC TRADING PLATFORMS. THE ISSUES WERE SELF-REPORTED TO THE CFTC, AND THE ORDER PROVIDED FOR A SUSTAINABLY REDUCED PENALTY IN RECOGNITION OF SG'S SELF-REPORTING, SUBSTANTIAL COOPERATION AND APPROPRIATE REMEDIATION.
Sanction detail — filed text
SG WAS FINED $1,500,000, ORDERED TO CEASE AND DESIST FROM VIOLATIONS OF RELEVANT SECTIONS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, AND REQUIRED TO PERFORM CERTAIN REMEDIAL UNDERTAKINGS INCLUDING PROVIDING BACK-REPORTED CORRECTED HISTORICAL VALUATIONS FOR LIVE SWAPS AFFECTED BY CALCULATION ISSUES TO THE SDR AND TO CLIENTS (UPON REQUEST), AS WELL AS SUBMITTING REMEDIAL REPORTS AT 120 DAYS AND 365 DAYS FOLLOWING THE ORDER.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) COMMODITY FUTURES TRADING COMMISSION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: UNDERTAKING 3. Date Initiated (MM/DD/YYYY): 09/29/2021 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CFTC DOCKET NO. 21-36 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Derivative(s) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE CFTC ALLEGED THAT FROM APPROXIMATELY 2013 TO JULY 2021, SOCIÉTÉ GÉNÉRALE (SG), AS A SWAP DEALER, FAILED TO DILIGENTLY SUPERVISE ITS PROCESS FOR DISCLOSING CFTC-REQUIRED MID-MARKET MARKS TO ELIGIBLE COUNTERPARTIES AND REPORTING VALUATIONS TO A SWAP DATA REPOSITORY (SDR). SPECIFICALLY, FOR MANY YEARS, SG FAILED TO DISCLOSE DAILY MID-MARKET MARKS ENTIRELY TO A SIGNIFICANT PORTION OF ELIGIBLE COUNTERPARTIES. FOR CERTAIN OTHER SWAPS, SG PROVIDED COUNTERPARTIES INACCURATE SWAP VALUATION DATA TO AN SDR. FINALLY, SG FAILED TO DISCLOSE PRE-TRADE MID-MARKET MARKS TO COUNTERPARTIES OVER CERTAIN ELECTRONIC TRADING PLATFORMS. THE ISSUES WERE SELF-REPORTED TO THE CFTC, AND THE ORDER PROVIDED FOR A SUSTAINABLY REDUCED PENALTY IN RECOGNITION OF SG'S SELF-REPORTING, SUBSTANTIAL COOPERATION AND APPROPRIATE REMEDIATION. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Decision & Order of Offer of Settlement 11. Resolution Date (MM/DD/YYYY): 09/29/2021 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 1,500,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SG WAS FINED $1,500,000, ORDERED TO CEASE AND DESIST FROM VIOLATIONS OF RELEVANT SECTIONS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, AND REQUIRED TO PERFORM CERTAIN REMEDIAL UNDERTAKINGS INCLUDING PROVIDING BACK-REPORTED CORRECTED HISTORICAL VALUATIONS FOR LIVE SWAPS AFFECTED BY CALCULATION ISSUES TO THE SDR AND TO CLIENTS (UPON REQUEST), AS WELL AS SUBMITTING REMEDIAL REPORTS AT 120 DAYS AND 365 DAYS FOLLOWING THE ORDER. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SG WAS FINED $1,500,000, ORDERED TO CEASE AND DESIST FROM VIOLATIONS OF RELEVANT SECTIONS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, AND REQUIRED TO PERFORM CERTAIN REMEDIAL UNDERTAKINGS INCLUDING PROVIDING BACK-REPORTED CORRECTED HISTORICAL VALUATIONS FOR LIVE SWAPS AFFECTED BY CALCULATION ISSUES TO THE SDR AND TO CLIENTS (UPON REQUEST), AS WELL AS SUBMITTING REMEDIAL REPORTS AT 120 DAYS AND 365 DAYS FOLLOWING THE ORDER.
regulatory · block 2SOCIÉTÉ GÉNÉRALE S.A.PDF pages 31–33
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- THE SECURITIES AND FUTURES COMMISSION (SFC) (HONG KONG)
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
WITHOUT ADMITTING LIABILITY, SOCIÉTÉ GÉNÉRALE AGREED TO ACCEPT A REPRIMAND FROM THE SFC AND TO REIMBURSE AFFECTED CUSTOMER THE FULL VALUE OF THE ALLEGEDLY UNDISCLOSED FEES TOGETHER WITH INTEREST. SOCIÉTÉ GÉNÉRALE ALSO AGREED TO ENGAGE AN INDEPENDENT REVIEWER TO ASSESS THE AMOUNT TO BE PAID TO ELIGIBLE CUSTOMERS. THE TOTAL AMOUNT TO BE REIMBURSED IS EXPECTED TO BE IN EXCESS OF $11 MILLION USD. SOCIÉTÉ GÉNÉRALE ALSO AGREED TO ENGAGE AN INDEPENDENT REVIEWER TO REVIEW THE CONTROLS, SYSTEMS, AND PROCEDURES OF ITS WEALTH MANAGEMENT UNIT IN HONG KONG IN RELATION TO ITS CURRENT PRACTICE IN CHARGING CUSTOMERS IN OTC TRANSACTIONS TO ENSURE THAT THEY ARE COMPLIANCE WITH LEGAL AND REGULATORY REQUIREMENTS.
Other filed details
Description of allegations — filed text
THE SECURITIES AND FUTURES COMMISSION (SFC) ALLEGED THAT, IN OVER 3000 TRANSACTIONS BETWEEN APRIL 2003 AND JANUARY 2006, SOCIÉTÉ GÉNÉRALE, HONG KONG BRANCH FAILED TO ADEQUATELY DISCLOSE TO CUSTOMERS OF ITS WEALTH MANAGEMENT UNIT CERTAIN FEES AND CHARGES IN SECONDARY MARKET TRANSACTIONS OF OVER-THE-COUNTER BONDS, OPTIONS AND STRUCTURED NOTES (OTC TRANSACTIONS).
Sanction detail — filed text
WITHOUT ADMITTING LIABILITY, SOCIÉTÉ GÉNÉRALE AGREED TO ACCEPT A REPRIMAND FROM THE SFC AND TO REIMBURSE AFFECTED CUSTOMERS THE FULL VALUE OF THE ALLEGEDLY UNDISCLOSED FEES TOGETHER WITH INTEREST. SOCIÉTÉ GÉNÉRALE ALSO AGREED TO ENGAGE AN INDEPENDENT REVIEWER TO ASSESS THE AMOUNT TO BE PAID TO ELIGIBLE CUSTOMERS. THE TOTAL AMOUNT TO BE REIMBURSED IS EXPECTED TO BE IN EXCESS OF $11 MILLION USD. SOCIÉTÉ GÉNÉRALE ALSO AGREED TO ENGAGE AN INDEPENDENT REVIEWER TO REVIEW THE CONTROLS, SYSTEMS, AND PROCEDURES OF ITS WEALTH MANAGEMENT UNIT IN HONG KONG IN RELATION TO ITS CURRENT PRACTICE IN CHARGING CUSTOMERS IN OTC TRANSACTIONS TO ENSURE THAT THEY ARE COMPLIANCE WITH LEGAL AND REGULATORY REQUIREMENTS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) THE SECURITIES AND FUTURES COMMISSION (SFC) (HONG KONG) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/17/2012 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: OVER-THE-COUNTER BONDS, OPTIONS, AND STRUCTURED NOTES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE SECURITIES AND FUTURES COMMISSION (SFC) ALLEGED THAT, IN OVER 3000 TRANSACTIONS BETWEEN APRIL 2003 AND JANUARY 2006, SOCIÉTÉ GÉNÉRALE, HONG KONG BRANCH FAILED TO ADEQUATELY DISCLOSE TO CUSTOMERS OF ITS WEALTH MANAGEMENT UNIT CERTAIN FEES AND CHARGES IN SECONDARY MARKET TRANSACTIONS OF OVER-THE-COUNTER BONDS, OPTIONS AND STRUCTURED NOTES (OTC TRANSACTIONS). 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Other 11. Resolution Date (MM/DD/YYYY): 07/17/2012 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: WITHOUT ADMITTING LIABILITY, SOCIÉTÉ GÉNÉRALE AGREED TO ACCEPT A REPRIMAND FROM THE SFC AND TO REIMBURSE AFFECTED CUSTOMERS THE FULL VALUE OF THE ALLEGEDLY UNDISCLOSED FEES TOGETHER WITH INTEREST. SOCIÉTÉ GÉNÉRALE ALSO AGREED TO ENGAGE AN INDEPENDENT REVIEWER TO ASSESS THE AMOUNT TO BE PAID TO ELIGIBLE CUSTOMERS. THE TOTAL AMOUNT TO BE REIMBURSED IS EXPECTED TO BE IN EXCESS OF $11 MILLION USD. SOCIÉTÉ GÉNÉRALE ALSO AGREED TO ENGAGE AN INDEPENDENT REVIEWER TO REVIEW THE CONTROLS, SYSTEMS, AND PROCEDURES OF ITS WEALTH MANAGEMENT UNIT IN HONG KONG IN RELATION TO ITS CURRENT PRACTICE IN CHARGING CUSTOMERS IN OTC TRANSACTIONS TO ENSURE THAT THEY ARE COMPLIANCE WITH LEGAL AND REGULATORY REQUIREMENTS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). WITHOUT ADMITTING LIABILITY, SOCIÉTÉ GÉNÉRALE AGREED TO ACCEPT A REPRIMAND FROM THE SFC AND TO REIMBURSE AFFECTED CUSTOMER THE FULL VALUE OF THE ALLEGEDLY UNDISCLOSED FEES TOGETHER WITH INTEREST. SOCIÉTÉ GÉNÉRALE ALSO AGREED TO ENGAGE AN INDEPENDENT REVIEWER TO ASSESS THE AMOUNT TO BE PAID TO ELIGIBLE CUSTOMERS. THE TOTAL AMOUNT TO BE REIMBURSED IS EXPECTED TO BE IN EXCESS OF $11 MILLION USD. SOCIÉTÉ GÉNÉRALE ALSO AGREED TO ENGAGE AN INDEPENDENT REVIEWER TO REVIEW THE CONTROLS, SYSTEMS, AND PROCEDURES OF ITS WEALTH MANAGEMENT UNIT IN HONG KONG IN RELATION TO ITS CURRENT PRACTICE IN CHARGING CUSTOMERS IN OTC TRANSACTIONS TO ENSURE THAT THEY ARE COMPLIANCE WITH LEGAL AND REGULATORY REQUIREMENTS.
regulatory · block 3SOCIÉTÉ GÉNÉRALE S.A.PDF pages 33–34
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE ("SG") FOR 18 MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN AUGUST 2021. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON SEPTEMBER 18, 2021, AFTER SG DETERMINED NOT TO SEEK WAIVER.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ICE CLEAR CREDIT LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
09/03/2021
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2021-404B-011
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
CREDIT DEFAULT SWAP
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE ("SG") FOR 18 MISSED END OF DAY CREDIT DEFAULT
SWAP PRICING SUBMISSIONS IN AUGUST 2021. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER
ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO
CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON SEPTEMBER 18, 2021, AFTER SG DETERMINED NOT TO SEEK WAIVER.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
09/18/2021
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 10,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR
MISSED SUBMISSIONS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED
SUBMISSIONS.regulatory · block 4SOCIÉTÉ GÉNÉRALE S.A.PDF pages 34–36
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- FINANCIAL MARKET AUTHORITY
- Monetary/Fine Amount — filed text
- $ 636,610.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
THE AMF FINED SOCIÉTÉ GÉNÉRALE 500,000 EUROS EQUALING $636,610 U.S. AS OF 11/7/2008.
Other filed details
Description of allegations — filed text
THE FINANCIAL MARKET AUTHORITY (AMF) FINED SOCIÉTÉ GÉNÉRALE 500,000 EUROS FOR (1) BREACHING ARTICLE 3326 OF THE GENERAL REGULATION OF AMF BY FAILING TO PROVE THE EXISTENCE OF CLIENT INSTRUCTIONS FOR A SIGNIFICANT NUMBER OF SUBSCRIPTIONS TO THE PUBLIC OFFERING BY THE EDF GROUP AND (2) BREACHING ARTICLES 321-24, 321-42, 321-47, AND 321-76 OF THE GENERAL REGULATION OF THE AMF BY REDUCING THE SIZE OF CERTAIN SUBSCRIPTION ORDERS AND FAILING TO HAVE IN PLACE SUFFICIENT SUPERVISORY TOOLS IN THIS AREA.
Sanction detail — filed text
THE AMF FINED SOCIÉTÉ GÉNÉRALE 500,000 EUROS EQUALING $636,610 U.S. AS OF 11/7/2008.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINANCIAL MARKET AUTHORITY 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 09/11/2008 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FINANCIAL MARKET AUTHORITY (AMF) FINED SOCIÉTÉ GÉNÉRALE 500,000 EUROS FOR (1) BREACHING ARTICLE 3326 OF THE GENERAL REGULATION OF AMF BY FAILING TO PROVE THE EXISTENCE OF CLIENT INSTRUCTIONS FOR A SIGNIFICANT NUMBER OF SUBSCRIPTIONS TO THE PUBLIC OFFERING BY THE EDF GROUP AND (2) BREACHING ARTICLES 321-24, 321-42, 321-47, AND 321-76 OF THE GENERAL REGULATION OF THE AMF BY REDUCING THE SIZE OF CERTAIN SUBSCRIPTION ORDERS AND FAILING TO HAVE IN PLACE SUFFICIENT SUPERVISORY TOOLS IN THIS AREA. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Decision 11. Resolution Date (MM/DD/YYYY): 11/07/2008 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 636,610.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE AMF FINED SOCIÉTÉ GÉNÉRALE 500,000 EUROS EQUALING $636,610 U.S. AS OF 11/7/2008. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE AMF FINED SOCIÉTÉ GÉNÉRALE 500,000 EUROS EQUALING $636,610 U.S. AS OF 11/7/2008.
Show 28 more source blocks
regulatory · block 5SOCIÉTÉ GÉNÉRALE S.A.PDF pages 36–38
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 1,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $1,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $1,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR 1 MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN MARCH 2019. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON APRIL 19, 2019, AFTER SG DETERMINED NOT TO SEEK WAIVER.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $1,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ICE CLEAR CREDIT LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
04/03/2019
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019-404B-002
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
CREDIT DEFAULT SWAP
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $1,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR 1 MISSED END OF DAY CREDIT DEFAULT SWAP
PRICING SUBMISSIONS IN MARCH 2019. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE
CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO
CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON APRIL 19, 2019, AFTER SG DETERMINED NOT TO SEEK WAIVER.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
04/19/2019
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 1,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ICE CLEAR ISSUED AN ASSESSMENT OF $1,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR
MISSED SUBMISSIONS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ICE CLEAR ISSUED AN ASSESSMENT OF $1,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED
SUBMISSIONS.regulatory · block 6SOCIÉTÉ GÉNÉRALE S.A.PDF pages 38–40
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT, LLC
- Monetary/Fine Amount — filed text
- $ 71,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $71,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSION.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT ("ICE CLEAR") ISSUED A $71,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR 7A MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN JULY 2022. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUES ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON AUGUST 17, 2022.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $71,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSION.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ICE CLEAR CREDIT, LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
08/02/2022
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2022-404B-020
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
CREDIT DEFAULT SWAP
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ICE CLEAR CREDIT ("ICE CLEAR") ISSUED A $71,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR 7A MISSED END OF DAY CREDIT DEFAULT SWAP
PRICING SUBMISSIONS IN JULY 2022. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE
CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUES ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO
CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON AUGUST 17, 2022.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
09/18/2022
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 71,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ICE CLEAR ISSUED AN ASSESSMENT OF $71,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR
MISSED SUBMISSION.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ICE CLEAR ISSUED AN ASSESSMENT OF $71,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED
SUBMISSION.regulatory · block 7SOCIÉTÉ GÉNÉRALE S.A.PDF pages 40–42
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
- Monetary/Fine Amount — filed text
- $ 325,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (COLLECTIVELY "SG"), ENTERED INTO A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (NYDFS) TO RESOLVE AN ENFORCEMENT ACTION BASED ON THE NYDFS'S FINDING THAT FROM 2003 TO 2013 SG FAILED TO TAKE SUFFICIENT STEPS TO ENSURE COMPLIANCE WITH THE U.S. SANCTIONS LAWS AND REGULATIONS IN A TIMELY MANNER. THE NYDFS FURTHER FOUND (1) THAT INDIVIDUALS RESPONSIBLE FOR ORIGINATING U.S. DOLLAR (USD) TRANSACTIONS OUTSIDE OF THE UNITED STATES HAD A MINIMAL UNDERSTANDING OF U.S. SANCTIONS LAWS AND REGULATIONS AS THEY RELATED TO SUDAN, IRAN, CUBA, NORTH KOREA, OR OTHER U.S. SANCTIONED COUNTRIES; (2) THAT SG EXECUTED MORE THAN 9,000 OUTBOUND USD PAYMENTS, VALUED AT OVER $13 BILLION, IN AN IMPROPER NON-TRANSPARENT MANNER, MORE THAN $12.5 BILLION OF WHICH INVOLVED IRAN, NEARLY $130 MILLION WERE CONNECTED TO CUBA, AND APPROXIMATELY $29 MILLION WERE TIED TO SUDAN; AND (3) THAT SG EXECUTED MORE THAN 2,600 OUTBOUND USD PAYMENTS VALUED APPROXIMATELY AT $8.3 BILLION, IN VIOLATION OF US ECONOMIC SANCTIONS, THE VAST MAJORITY OF WHICH WERE LINKED TO CUBA. THIS CONDUCT RESULTED IN MULTIPLE VIOLATIONS OF NEW YORK STATE LAWS AND REGULATIONS. SG AGREED TO PAY A PENALTY OF $325,000,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE ON THE NYDFS WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS, SPECIFICALLY A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AND DPA WITH THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH THE U.S. DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL (WITH A PENALTY OF $53.9 MILLION), AND AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNOR OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION).
Other filed details
Description of allegations — filed text
ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (COLLECTIVELY "SG"), ENTERED INTO A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (NYDFS) TO RESOLVE AN ENFORCEMENT ACTION BASED ON THE NYDFS'S FINDING THAT FROM 2003 TO 2013 SG FAILED TO TAKE SUFFICIENT STEPS TO ENSURE COMPLIANCE WITH THE U.S. SANCTIONS LAWS AND REGULATIONS IN A TIMELY MANNER. THE NYDFS FURTHER FOUND (1) THAT INDIVIDUALS RESPONSIBLE FOR ORIGINATING U.S. DOLLAR (USD) TRANSACTIONS OUTSIDE OF THE UNITED STATES HAD A MINIMAL UNDERSTANDING OF U.S. SANCTIONS LAWS AND REGULATIONS AS THEY RELATED TO SUDAN, IRAN, CUBA, NORTH KOREA, OR OTHER U.S. SANCTIONED COUNTRIES; (2) THAT SG EXECUTED MORE THAN 9,000 OUTBOUND USD PAYMENTS, VALUED AT OVER $13 BILLION, IN AN IMPROPER NON-TRANSPARENT MANNER, MORE THAN $12.5 BILLION OF WHICH INVOLVED IRAN, NEARLY $130 MILLION WERE CONNECTED TO CUBA, AND APPROXIMATELY $29 MILLION WERE TIED TO SUDAN; AND (3) THAT SG EXECUTED MORE THAN 2,600 OUTBOUND USD PAYMENTS VALUED APPROXIMATELY AT $8.3 BILLION, IN VIOLATION OF US ECONOMIC SANCTIONS, THE VAST MAJORITY OF WHICH WERE LINKED TO CUBA. THIS CONDUCT RESULTED IN MULTIPLE VIOLATIONS OF NEW YORK STATE LAWS AND REGULATIONS. SG AGREED TO PAY A PENALTY OF $325,000,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE ON THE NYDFS WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS, SPECIFICALLY A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AND DPA WITH THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH THE U.S. DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL (WITH A PENALTY OF $53.9 MILLION), AND AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNOR OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION).
Sanction detail — filed text
ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (COLLECTIVELY "SG"), ENTERED INTO A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (NYDFS) TO RESOLVE AN ENFORCEMENT ACTION BASED ON THE NYDFS'S FINDING THAT FROM 2003 TO 2013 SG FAILED TO TAKE SUFFICIENT STEPS TO ENSURE COMPLIANCE WITH THE U.S. SANCTIONS LAWS AND REGULATIONS IN A TIMELY MANNER. THE NYDFS FURTHER FOUND (1) THAT INDIVIDUALS RESPONSIBLE FOR ORIGINATING U.S. DOLLAR (USD) TRANSACTIONS OUTSIDE OF THE UNITED STATES HAD A MINIMAL UNDERSTANDING OF U.S. SANCTIONS LAWS AND REGULATIONS AS THEY RELATED TO SUDAN, IRAN, CUBA, NORTH KOREA, OR OTHER U.S. SANCTIONED COUNTRIES; (2) THAT SG EXECUTED MORE THAN 9,000 OUTBOUND USD PAYMENTS, VALUED AT OVER $13 BILLION, IN AN IMPROPER NON-TRANSPARENT MANNER, MORE THAN $12.5 BILLION OF WHICH INVOLVED IRAN, NEARLY $130 MILLION WERE CONNECTED TO CUBA, AND APPROXIMATELY $29 MILLION WERE TIED TO SUDAN; AND (3) THAT SG EXECUTED MORE THAN 2,600 OUTBOUND USD PAYMENTS VALUED APPROXIMATELY AT $8.3 BILLION, IN VIOLATION OF US ECONOMIC SANCTIONS, THE VAST MAJORITY OF WHICH WERE LINKED TO CUBA. THIS CONDUCT RESULTED IN MULTIPLE VIOLATIONS OF NEW YORK STATE LAWS AND REGULATIONS. SG AGREED TO PAY A PENALTY OF $325,000,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE ON THE NYDFS WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS, SPECIFICALLY A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AND DPA WITH THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH THE U.S. DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL (WITH A PENALTY OF $53.9 MILLION), AND AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNOR OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION).
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 11/19/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (COLLECTIVELY "SG"), ENTERED INTO A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (NYDFS) TO RESOLVE AN ENFORCEMENT ACTION BASED ON THE NYDFS'S FINDING THAT FROM 2003 TO 2013 SG FAILED TO TAKE SUFFICIENT STEPS TO ENSURE COMPLIANCE WITH THE U.S. SANCTIONS LAWS AND REGULATIONS IN A TIMELY MANNER. THE NYDFS FURTHER FOUND (1) THAT INDIVIDUALS RESPONSIBLE FOR ORIGINATING U.S. DOLLAR (USD) TRANSACTIONS OUTSIDE OF THE UNITED STATES HAD A MINIMAL UNDERSTANDING OF U.S. SANCTIONS LAWS AND REGULATIONS AS THEY RELATED TO SUDAN, IRAN, CUBA, NORTH KOREA, OR OTHER U.S. SANCTIONED COUNTRIES; (2) THAT SG EXECUTED MORE THAN 9,000 OUTBOUND USD PAYMENTS, VALUED AT OVER $13 BILLION, IN AN IMPROPER NON-TRANSPARENT MANNER, MORE THAN $12.5 BILLION OF WHICH INVOLVED IRAN, NEARLY $130 MILLION WERE CONNECTED TO CUBA, AND APPROXIMATELY $29 MILLION WERE TIED TO SUDAN; AND (3) THAT SG EXECUTED MORE THAN 2,600 OUTBOUND USD PAYMENTS VALUED APPROXIMATELY AT $8.3 BILLION, IN VIOLATION OF US ECONOMIC SANCTIONS, THE VAST MAJORITY OF WHICH WERE LINKED TO CUBA. THIS CONDUCT RESULTED IN MULTIPLE VIOLATIONS OF NEW YORK STATE LAWS AND REGULATIONS. SG AGREED TO PAY A PENALTY OF $325,000,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE ON THE NYDFS WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS, SPECIFICALLY A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AND DPA WITH THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH THE U.S. DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL (WITH A PENALTY OF $53.9 MILLION), AND AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNOR OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION). 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Order 11. Resolution Date (MM/DD/YYYY): 11/19/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 325,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (COLLECTIVELY "SG"), ENTERED INTO A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (NYDFS) TO RESOLVE AN ENFORCEMENT ACTION BASED ON THE NYDFS'S FINDING THAT FROM 2003 TO 2013 SG FAILED TO TAKE SUFFICIENT STEPS TO ENSURE COMPLIANCE WITH THE U.S. SANCTIONS LAWS AND REGULATIONS IN A TIMELY MANNER. THE NYDFS FURTHER FOUND (1) THAT INDIVIDUALS RESPONSIBLE FOR ORIGINATING U.S. DOLLAR (USD) TRANSACTIONS OUTSIDE OF THE UNITED STATES HAD A MINIMAL UNDERSTANDING OF U.S. SANCTIONS LAWS AND REGULATIONS AS THEY RELATED TO SUDAN, IRAN, CUBA, NORTH KOREA, OR OTHER U.S. SANCTIONED COUNTRIES; (2) THAT SG EXECUTED MORE THAN 9,000 OUTBOUND USD PAYMENTS, VALUED AT OVER $13 BILLION, IN AN IMPROPER NON-TRANSPARENT MANNER, MORE THAN $12.5 BILLION OF WHICH INVOLVED IRAN, NEARLY $130 MILLION WERE CONNECTED TO CUBA, AND APPROXIMATELY $29 MILLION WERE TIED TO SUDAN; AND (3) THAT SG EXECUTED MORE THAN 2,600 OUTBOUND USD PAYMENTS VALUED APPROXIMATELY AT $8.3 BILLION, IN VIOLATION OF US ECONOMIC SANCTIONS, THE VAST MAJORITY OF WHICH WERE LINKED TO CUBA. THIS CONDUCT RESULTED IN MULTIPLE VIOLATIONS OF NEW YORK STATE LAWS AND REGULATIONS. SG AGREED TO PAY A PENALTY OF $325,000,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE ON THE NYDFS WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS, SPECIFICALLY A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AND DPA WITH THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH THE U.S. DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL (WITH A PENALTY OF $53.9 MILLION), AND AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNOR OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION). 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (COLLECTIVELY "SG"), ENTERED INTO A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (NYDFS) TO RESOLVE AN ENFORCEMENT ACTION BASED ON THE NYDFS'S FINDING THAT FROM 2003 TO 2013 SG FAILED TO TAKE SUFFICIENT STEPS TO ENSURE COMPLIANCE WITH THE U.S. SANCTIONS LAWS AND REGULATIONS IN A TIMELY MANNER. THE NYDFS FURTHER FOUND (1) THAT INDIVIDUALS RESPONSIBLE FOR ORIGINATING U.S. DOLLAR (USD) TRANSACTIONS OUTSIDE OF THE UNITED STATES HAD A MINIMAL UNDERSTANDING OF U.S. SANCTIONS LAWS AND REGULATIONS AS THEY RELATED TO SUDAN, IRAN, CUBA, NORTH KOREA, OR OTHER U.S. SANCTIONED COUNTRIES; (2) THAT SG EXECUTED MORE THAN 9,000 OUTBOUND USD PAYMENTS, VALUED AT OVER $13 BILLION, IN AN IMPROPER NON-TRANSPARENT MANNER, MORE THAN $12.5 BILLION OF WHICH INVOLVED IRAN, NEARLY $130 MILLION WERE CONNECTED TO CUBA, AND APPROXIMATELY $29 MILLION WERE TIED TO SUDAN; AND (3) THAT SG EXECUTED MORE THAN 2,600 OUTBOUND USD PAYMENTS VALUED APPROXIMATELY AT $8.3 BILLION, IN VIOLATION OF US ECONOMIC SANCTIONS, THE VAST MAJORITY OF WHICH WERE LINKED TO CUBA. THIS CONDUCT RESULTED IN MULTIPLE VIOLATIONS OF NEW YORK STATE LAWS AND REGULATIONS. SG AGREED TO PAY A PENALTY OF $325,000,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE ON THE NYDFS WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS, SPECIFICALLY A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AND DPA WITH THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH THE U.S. DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL (WITH A PENALTY OF $53.9 MILLION), AND AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNOR OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION).
regulatory · block 8SOCIÉTÉ GÉNÉRALE S.A.PDF pages 42–44
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- AUTORITE DES MARCHES FINANCIERS ("AMF")
- Monetary/Fine Amount — filed text
- $ 651,200.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
THE AMF FINED SOCIÉTÉ GÉNÉRALE AND ANOTHER FRENCH BANK 500,000 EUR ($651,200.00 USD) EACH FOR FAILING TO ENSURE THE CONFIDENTIALITY OF INFORMATION WHEN TESTING INTEREST IN BOND SALES IN 2009.
Other filed details
Description of allegations — filed text
THE AMF FINED SOCIÉTÉ GÉNÉRALE AND ANOTHER FRENCH BANK 500,000 EUR ($651,200.00 USD) EACH FOR FAILING TO ENSURE THE CONFIDENTIALITY OF INFORMATION WHEN TESTING INTEREST IN BOND SALES IN 2009.
Sanction detail — filed text
THE AMF FINED SOCIÉTÉ GÉNÉRALE AND ANOTHER FRENCH BANK 500,000 EUR ($651,200.00 USD) EACH FOR FAILING TO ENSURE THE CONFIDENTIALITY OF INFORMATION WHEN TESTING INTEREST IN BOND SALES IN 2009.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
AUTORITE DES MARCHES FINANCIERS ("AMF")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
03/22/2012
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE AMF FINED SOCIÉTÉ GÉNÉRALE AND ANOTHER FRENCH BANK 500,000 EUR ($651,200.00 USD) EACH FOR FAILING TO ENSURE THE
CONFIDENTIALITY OF INFORMATION WHEN TESTING INTEREST IN BOND SALES IN 2009.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
03/22/2012
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 651,200.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE AMF FINED SOCIÉTÉ GÉNÉRALE AND ANOTHER FRENCH BANK 500,000 EUR ($651,200.00 USD) EACH FOR FAILING TO ENSURE THE
CONFIDENTIALITY OF INFORMATION WHEN TESTING INTEREST IN BOND SALES IN 2009.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE AMF FINED SOCIÉTÉ GÉNÉRALE AND ANOTHER FRENCH BANK 500,000 EUR ($651,200.00 USD) EACH FOR FAILING TO ENSURE THE
CONFIDENTIALITY OF INFORMATION WHEN TESTING INTEREST IN BOND SALES IN 2009.regulatory · block 9SOCIÉTÉ GÉNÉRALE S.A.PDF pages 44–46
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- BANQUE DE FRANCE (BDF)
- Monetary/Fine Amount — filed text
- $ 70,738.47
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
THE BDF ORDERED SG TO PAY A FINE OF EUR 62,379.60 FOR PURPOSES OF THIS FILING THE FINE HAS BEEN CONVERTED FROM EUR TO USD BASED UPON A 1 EUR TO 1.134 USD EXCHANGE RATE AS OF FEBRUARY 22, 2022.
Other filed details
Description of allegations — filed text
SOCIÉTÉ GÉNÉRALE (SG) WAS THE SUBJECT OF AN ONSITE EXAMINATION IN 2019 FROM THE BDF CONCERNING THE ELIGIBILITY OF PRIVATE LOANS REMITTED AS COLLATERAL FOR SG'S INTRA-DAY REFINANCING FROM THE BDF. THE BDF FOUND THAT CERTAIN OF THE PRIVATE LOANS SUBMITTED BY SG DID NOT COMPLY WITH FRENCH REGULATORY PROVISIONS REGARDING THE TYPES OF LOANS THAT WERE ELIGIBLE FOR COLLATERAL. THE ISSUES IDENTIFIED BY THE BDF INCLUDED AMONG OTHERS AN IMPERMISSIBLE RATE STRUCTURE FOR CERTAIN OF THE LOANS; LACK OF PROPER DOCUMENTATION; AND IMPERMISSIBLE GOVERNING LAW.
Sanction detail — filed text
THE BDF ORDERED SG TO PAY A FINE OF EUR 62,379.60 FOR PURPOSES OF THIS FILING THE FINE HAS BEEN CONVERTED FROM EUR TO USD BASED UPON A 1 EUR TO 1.134 USD EXCHANGE RATE AS OF FEBRUARY 22, 2022.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) BANQUE DE FRANCE (BDF) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 02/22/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): SOCIÉTÉ GÉNÉRALE (SG) WAS THE SUBJECT OF AN ONSITE EXAMINATION IN 2019 FROM THE BDF CONCERNING THE ELIGIBILITY OF PRIVATE LOANS REMITTED AS COLLATERAL FOR SG'S INTRA-DAY REFINANCING FROM THE BDF. THE BDF FOUND THAT CERTAIN OF THE PRIVATE LOANS SUBMITTED BY SG DID NOT COMPLY WITH FRENCH REGULATORY PROVISIONS REGARDING THE TYPES OF LOANS THAT WERE ELIGIBLE FOR COLLATERAL. THE ISSUES IDENTIFIED BY THE BDF INCLUDED AMONG OTHERS AN IMPERMISSIBLE RATE STRUCTURE FOR CERTAIN OF THE LOANS; LACK OF PROPER DOCUMENTATION; AND IMPERMISSIBLE GOVERNING LAW. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Decision 11. Resolution Date (MM/DD/YYYY): 02/22/2022 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 70,738.47 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE BDF ORDERED SG TO PAY A FINE OF EUR 62,379.60 FOR PURPOSES OF THIS FILING THE FINE HAS BEEN CONVERTED FROM EUR TO USD BASED UPON A 1 EUR TO 1.134 USD EXCHANGE RATE AS OF FEBRUARY 22, 2022. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE BDF ORDERED SG TO PAY A FINE OF EUR 62,379.60 FOR PURPOSES OF THIS FILING THE FINE HAS BEEN CONVERTED FROM EUR TO USD BASED UPON A 1 EUR TO 1.134 USD EXCHANGE RATE AS OF FEBRUARY 22, 2022.
regulatory · block 10SOCIÉTÉ GÉNÉRALE S.A.PDF pages 46–48
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- THE FINANCIAL SERVICES AUTHORITY - UNITED KINGDOM
- Monetary/Fine Amount — filed text
- $ 2,420,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
SOCIÉTÉ GÉNÉRALE WAS FINED 1.575 MILLION BRITISH POUNDS.
Other filed details
Description of allegations — filed text
DURING THE PERIOD FROM NOVEMBER 2007 TO FEBRUARY 2012, SOCIÉTÉ GÉNÉRALE IN THE UNITED KINGDOM (1) DID NOT SUBMIT TRADE REPORTING DATA FOR REPORTABLE TRANSACTIONS OR SUBMITTED INACCURATE DATA IN SUCH REPORTS IN 18.8 MILLION OF ITS 23.5 MILLION REPORTABLE TRANSACTIONS, AND (2) DID NOT RETAIN AND HAVE AVAILABLE SUCH TRADE REPORTING DATA, IN VIOLATION OF FSA RULES.
Sanction detail — filed text
SOCIÉTÉ GÉNÉRALE WAS FINED 1.575 MILLION BRITISH POUNDS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) THE FINANCIAL SERVICES AUTHORITY - UNITED KINGDOM 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 08/25/2010 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): DURING THE PERIOD FROM NOVEMBER 2007 TO FEBRUARY 2012, SOCIÉTÉ GÉNÉRALE IN THE UNITED KINGDOM (1) DID NOT SUBMIT TRADE REPORTING DATA FOR REPORTABLE TRANSACTIONS OR SUBMITTED INACCURATE DATA IN SUCH REPORTS IN 18.8 MILLION OF ITS 23.5 MILLION REPORTABLE TRANSACTIONS, AND (2) DID NOT RETAIN AND HAVE AVAILABLE SUCH TRADE REPORTING DATA, IN VIOLATION OF FSA RULES. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Settled 11. Resolution Date (MM/DD/YYYY): 08/25/2010 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 2,420,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SOCIÉTÉ GÉNÉRALE WAS FINED 1.575 MILLION BRITISH POUNDS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SOCIÉTÉ GÉNÉRALE WAS FINED 1.575 MILLION BRITISH POUNDS.
regulatory · block 11SOCIÉTÉ GÉNÉRALE S.A.PDF pages 48–50
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- U.S. DEPARTMENT OF TREASURY, OFFICE OF FOREIGN ASSET CONTROL
- Monetary/Fine Amount — filed text
- $ 53,966,916.05
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE ENTERED INTO A SETTLEMENT AGREEMENT WITH THE US DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL ("OFAC") CONCERNING APPARENT VIOLATIONS OF US ECONOMIC SANCTIONS LAWS. SG AGREED TO PAY A PENALTY OF $53,966.916.05. IN THE SETTLEMENT, OFAC ALLEGED THAT FOR AT LEAST FIVE YEARS UP TO AND INCLUDING 2012, SG THROUGH ITS HEADQUARTERS AND VARIOUS BRANCHES, PROCESSED 1,077 US DOLLAR (USD) TRANSACTIONS THROUGH US FINANCIAL INSTITUTIONS TOTALING $5,560,452,994.36 THAT APPEAR TO HAVE VIOLATED THE FOLLOWING SANCTIONS PROGRAMS: THE CUBAN ASSETS CONTROL REGULATIONS, 31 CFR PART 515; THE SUDANESE SANCTIONS REGULATIONS, 31 CFR PART 538; AND THE IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS, 31 CFR PART 560. OFAC FURTHER ALLEGED THAT SG PROCESSED THESE TRANSACTIONS IN A NON-TRANSPARENT MANNER THAT REMOVED, OMITTED, OBSCURED, OR OTHERWISE FAILED TO INCLUDE REFERENCES TO OFAC-SANCTIONED PARTIES IN THE INFORMATION SENT TO THE US FINANCIAL INSTITUTIONS THAT WERE INVOLVED IN THE TRANSACTIONS. A COPY OF THE OFAC SETTLEMENT AGREEMENT IS AVAILABLE ON THE OFAC WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENTS, INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONETARY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION).
Other filed details
Description of allegations — filed text
ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE ENTERED INTO A SETTLEMENT AGREEMENT WITH THE US DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL ("OFAC") CONCERNING APPARENT VIOLATIONS OF US ECONOMIC SANCTIONS LAWS. SG AGREED TO PAY A PENALTY OF $53,966.916.05. IN THE SETTLEMENT, OFAC ALLEGED THAT FOR AT LEAST FIVE YEARS UP TO AND INCLUDING 2012, SG THROUGH ITS HEADQUARTERS AND VARIOUS BRANCHES, PROCESSED 1,077 US DOLLAR (USD) TRANSACTIONS THROUGH US FINANCIAL INSTITUTIONS TOTALING $5,560,452,994.36 THAT APPEAR TO HAVE VIOLATED THE FOLLOWING SANCTIONS PROGRAMS: THE CUBAN ASSETS CONTROL REGULATIONS, 31 CFR PART 515; THE SUDANESE SANCTIONS REGULATIONS, 31 CFR PART 538; AND THE IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS, 31 CFR PART 560. OFAC FURTHER ALLEGED THAT SG PROCESSED THESE TRANSACTIONS IN A NON-TRANSPARENT MANNER THAT REMOVED, OMITTED, OBSCURED, OR OTHERWISE FAILED TO INCLUDE REFERENCES TO OFAC-SANCTIONED PARTIES IN THE INFORMATION SENT TO THE US FINANCIAL INSTITUTIONS THAT WERE INVOLVED IN THE TRANSACTIONS. A COPY OF THE OFAC SETTLEMENT AGREEMENT IS AVAILABLE ON THE OFAC WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENTS, INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONETARY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION).
Sanction detail — filed text
ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE ENTERED INTO A SETTLEMENT AGREEMENT WITH THE US DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL ("OFAC") CONCERNING APPARENT VIOLATIONS OF US ECONOMIC SANCTIONS LAWS. SG AGREED TO PAY A PENALTY OF $53,966.916.05. IN THE SETTLEMENT, OFAC ALLEGED THAT FOR AT LEAST FIVE YEARS UP TO AND INCLUDING 2012, SG THROUGH ITS HEADQUARTERS AND VARIOUS BRANCHES, PROCESSED 1,077 US DOLLAR (USD) TRANSACTIONS THROUGH US FINANCIAL INSTITUTIONS TOTALING $5,560,452,994.36 THAT APPEAR TO HAVE VIOLATED THE FOLLOWING SANCTIONS PROGRAMS: THE CUBAN ASSETS CONTROL REGULATIONS, 31 CFR PART 515; THE SUDANESE SANCTIONS REGULATIONS, 31 CFR PART 538; AND THE IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS, 31 CFR PART 560. OFAC FURTHER ALLEGED THAT SG PROCESSED THESE TRANSACTIONS IN A NON-TRANSPARENT MANNER THAT REMOVED, OMITTED, OBSCURED, OR OTHERWISE FAILED TO INCLUDE REFERENCES TO OFAC-SANCTIONED PARTIES IN THE INFORMATION SENT TO THE US FINANCIAL INSTITUTIONS THAT WERE INVOLVED IN THE TRANSACTIONS. A COPY OF THE OFAC SETTLEMENT AGREEMENT IS AVAILABLE ON THE OFAC WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENTS, INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONETARY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION).
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
U.S. DEPARTMENT OF TREASURY, OFFICE OF FOREIGN ASSET CONTROL
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
11/19/2019
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CPMPL-2014-206959
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE ENTERED INTO A SETTLEMENT AGREEMENT WITH THE US DEPARTMENT OF TREASURY'S OFFICE OF
FOREIGN ASSET CONTROL ("OFAC") CONCERNING APPARENT VIOLATIONS OF US ECONOMIC SANCTIONS LAWS. SG AGREED TO PAY A PENALTY OF
$53,966.916.05. IN THE SETTLEMENT, OFAC ALLEGED THAT FOR AT LEAST FIVE YEARS UP TO AND INCLUDING 2012, SG THROUGH ITS HEADQUARTERS
AND VARIOUS BRANCHES, PROCESSED 1,077 US DOLLAR (USD) TRANSACTIONS THROUGH US FINANCIAL INSTITUTIONS TOTALING $5,560,452,994.36
THAT APPEAR TO HAVE VIOLATED THE FOLLOWING SANCTIONS PROGRAMS: THE CUBAN ASSETS CONTROL REGULATIONS, 31 CFR PART 515; THE
SUDANESE SANCTIONS REGULATIONS, 31 CFR PART 538; AND THE IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS, 31 CFR PART 560. OFAC
FURTHER ALLEGED THAT SG PROCESSED THESE TRANSACTIONS IN A NON-TRANSPARENT MANNER THAT REMOVED, OMITTED, OBSCURED, OR
OTHERWISE FAILED TO INCLUDE REFERENCES TO OFAC-SANCTIONED PARTIES IN THE INFORMATION SENT TO THE US FINANCIAL INSTITUTIONS THAT
WERE INVOLVED IN THE TRANSACTIONS. A COPY OF THE OFAC SETTLEMENT AGREEMENT IS AVAILABLE ON THE OFAC WEBSITE. SG ALSO ENTERED
INTO CERTAIN RELATED SETTLEMENTS, INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE US DEPARTMENT OF JUSTICE (WITH A
PENALTY OF $717.2 MILLION), AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONETARY PENALTY ISSUED ON CONSENT BY
THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW
YORK STATE DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION).
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
11/19/2018
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 53,966,916.05
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE ENTERED INTO A SETTLEMENT AGREEMENT WITH THE US DEPARTMENT OF TREASURY'S OFFICE OF
FOREIGN ASSET CONTROL ("OFAC") CONCERNING APPARENT VIOLATIONS OF US ECONOMIC SANCTIONS LAWS. SG AGREED TO PAY A PENALTY
OF $53,966.916.05. IN THE SETTLEMENT, OFAC ALLEGED THAT FOR AT LEAST FIVE YEARS UP TO AND INCLUDING 2012, SG THROUGH ITS
HEADQUARTERS AND VARIOUS BRANCHES, PROCESSED 1,077 US DOLLAR (USD) TRANSACTIONS THROUGH US FINANCIAL INSTITUTIONS
TOTALING $5,560,452,994.36 THAT APPEAR TO HAVE VIOLATED THE FOLLOWING SANCTIONS PROGRAMS: THE CUBAN ASSETS CONTROL
REGULATIONS, 31 CFR PART 515; THE SUDANESE SANCTIONS REGULATIONS, 31 CFR PART 538; AND THE IRANIAN TRANSACTIONS AND
SANCTIONS REGULATIONS, 31 CFR PART 560. OFAC FURTHER ALLEGED THAT SG PROCESSED THESE TRANSACTIONS IN A NON-TRANSPARENT
MANNER THAT REMOVED, OMITTED, OBSCURED, OR OTHERWISE FAILED TO INCLUDE REFERENCES TO OFAC-SANCTIONED PARTIES IN THE
INFORMATION SENT TO THE US FINANCIAL INSTITUTIONS THAT WERE INVOLVED IN THE TRANSACTIONS. A COPY OF THE OFAC SETTLEMENT
AGREEMENT IS AVAILABLE ON THE OFAC WEBSITE. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENTS, INCLUDING A DEFERRED
PROSECUTION AGREEMENT (DPA) WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), AN ORDER TO CEASE AND
DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONETARY PENALTY ISSUED ON CONSENT BY THE BOARD OF GOVERNORS OF THE FEDERAL
RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL
SERVICES (WITH A PENALTY OF $325 MILLION).
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON NOVEMBER 19, 2018, SOCIÉTÉ GÉNÉRALE ENTERED INTO A SETTLEMENT AGREEMENT WITH THE US DEPARTMENT OF TREASURY'S OFFICE OF
FOREIGN ASSET CONTROL ("OFAC") CONCERNING APPARENT VIOLATIONS OF US ECONOMIC SANCTIONS LAWS. SG AGREED TO PAY A PENALTY OF
$53,966.916.05. IN THE SETTLEMENT, OFAC ALLEGED THAT FOR AT LEAST FIVE YEARS UP TO AND INCLUDING 2012, SG THROUGH ITS HEADQUARTERS
AND VARIOUS BRANCHES, PROCESSED 1,077 US DOLLAR (USD) TRANSACTIONS THROUGH US FINANCIAL INSTITUTIONS TOTALING $5,560,452,994.36
THAT APPEAR TO HAVE VIOLATED THE FOLLOWING SANCTIONS PROGRAMS: THE CUBAN ASSETS CONTROL REGULATIONS, 31 CFR PART 515; THE
SUDANESE SANCTIONS REGULATIONS, 31 CFR PART 538; AND THE IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS, 31 CFR PART 560. OFAC
FURTHER ALLEGED THAT SG PROCESSED THESE TRANSACTIONS IN A NON-TRANSPARENT MANNER THAT REMOVED, OMITTED, OBSCURED, OR
OTHERWISE FAILED TO INCLUDE REFERENCES TO OFAC-SANCTIONED PARTIES IN THE INFORMATION SENT TO THE US FINANCIAL INSTITUTIONS THAT
WERE INVOLVED IN THE TRANSACTIONS. A COPY OF THE OFAC SETTLEMENT AGREEMENT IS AVAILABLE ON THE OFAC WEBSITE. SG ALSO ENTERED
INTO CERTAIN RELATED SETTLEMENTS, INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA) WITH THE US DEPARTMENT OF JUSTICE (WITH A
PENALTY OF $717.2 MILLION), AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONETARY PENALTY ISSUED ON CONSENT BY
THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW
YORK STATE DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION).regulatory · block 12SOCIÉTÉ GÉNÉRALE S.A.PDF pages 50–52
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON NOVEMBER 19, 2018, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ISSUED A CONSENTED-TO ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF CIVIL MONETARY PENALTY AGAINST SOCIÉTÉ GÉNÉRALE (SG) WITH RESPECT TO THE FOLLOWING: (1) A LACK OF ADEQUATE TRANSPARENCY, RISK MANAGEMENT, AND LEGAL AND COMPLIANCE REVIEW POLICIES AND PROCEDURES TO ENSURE THAT ACTIVITIES CONDUCTED AT SG'S OFFICES OUTSIDE OF THE UNITED STATES, PRIMARILY THROUGH THE SG'S CORPORATE AND INVESTMENT BANKING OPERATIONS, COMPILED WITH APPLICABLE REGULATIONS OF THE U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL (OFAC); AND (2) FROM AT LEAST 2007 TO 2012, AMONG OTHER THINGS, CERTAIN NON-US OFFICES, PRINCIPALLY SG IN FRANCE PROCESSED US DOLLAR DENOMINATED FUNDS TRANSFERS THROUGH THE SG'S NEW YORK BRANCH AND THROUGH UNAFFILIATED US FINANCIAL INSTITUTIONS INVOLVING PARTIES SUBJECT TO OFAC SANCTIONS THAT DID NOT CONTAIN RELEVANT INFORMATION WITHIN THE PAYMENT MESSAGES NECESSARY FOR THE US FINANCIAL INSTITUTIONS TO DETERMINE WHETHER THESE TRANSACTIONS WERE CARRIED OUT IN A MANNER CONSISTENT WITH US LAWS, WHICH RESULTED IN VIOLATIONS OF OFAC REGULATIONS. SG AGREED TO PAY A PENALTY OF $81,265,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CEASE AND DESIST ORDER IS AVAILABLE ON THE WEBSITE OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA), WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTRY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH OFAC (WITH A PENALTY OF $53.9 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION).
Other filed details
Description of allegations — filed text
ON NOVEMBER 19, 2018, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ISSUED A CONSENTED-TO ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF CIVIL MONETARY PENALTY AGAINST SOCIÉTÉ GÉNÉRALE (SG) WITH RESPECT TO THE FOLLOWING: (1) A LACK OF ADEQUATE TRANSPARENCY, RISK MANAGEMENT, AND LEGAL AND COMPLIANCE REVIEW POLICIES AND PROCEDURES TO ENSURE THAT ACTIVITIES CONDUCTED AT SG'S OFFICES OUTSIDE OF THE UNITED STATES, PRIMARILY THROUGH THE SG'S CORPORATE AND INVESTMENT BANKING OPERATIONS, COMPILED WITH APPLICABLE REGULATIONS OF THE U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL (OFAC); AND (2) FROM AT LEAST 2007 TO 2012, AMONG OTHER THINGS, CERTAIN NON-US OFFICES, PRINCIPALLY SG IN FRANCE PROCESSED US DOLLAR DENOMINATED FUNDS TRANSFERS THROUGH THE SG'S NEW YORK BRANCH AND THROUGH UNAFFILIATED US FINANCIAL INSTITUTIONS INVOLVING PARTIES SUBJECT TO OFAC SANCTIONS THAT DID NOT CONTAIN RELEVANT INFORMATION WITHIN THE PAYMENT MESSAGES NECESSARY FOR THE US FINANCIAL INSTITUTIONS TO DETERMINE WHETHER THESE TRANSACTIONS WERE CARRIED OUT IN A MANNER CONSISTENT WITH US LAWS, WHICH RESULTED IN VIOLATIONS OF OFAC REGULATIONS. SG AGREED TO PAY A PENALTY OF $81,265,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CEASE AND DESIST ORDER IS AVAILABLE ON THE WEBSITE OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA), WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTRY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH OFAC (WITH A PENALTY OF $53.9 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE ) ( ) DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION).
Sanction detail — filed text
SG AGREED TO PAY A PENALTY OF $81,265,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CEASE AND DESIST ORDER IS AVAILABLE ON THE WEBSITE OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA), WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTRY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH OFAC (WITH A PENALTY OF $53.9 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION).
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM 2. Principal Sanction: Cease and Desist Other Sanctions: CIVIL MONETARY PENALTY, AS DESCRIBED BELOW. 3. Date Initiated (MM/DD/YYYY): 11/19/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 18-031-B-FB; 18-031-CMP-FB 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON NOVEMBER 19, 2018, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ISSUED A CONSENTED-TO ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF CIVIL MONETARY PENALTY AGAINST SOCIÉTÉ GÉNÉRALE (SG) WITH RESPECT TO THE FOLLOWING: (1) A LACK OF ADEQUATE TRANSPARENCY, RISK MANAGEMENT, AND LEGAL AND COMPLIANCE REVIEW POLICIES AND PROCEDURES TO ENSURE THAT ACTIVITIES CONDUCTED AT SG'S OFFICES OUTSIDE OF THE UNITED STATES, PRIMARILY THROUGH THE SG'S CORPORATE AND INVESTMENT BANKING OPERATIONS, COMPILED WITH APPLICABLE REGULATIONS OF THE U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL (OFAC); AND (2) FROM AT LEAST 2007 TO 2012, AMONG OTHER THINGS, CERTAIN NON-US OFFICES, PRINCIPALLY SG IN FRANCE PROCESSED US DOLLAR DENOMINATED FUNDS TRANSFERS THROUGH THE SG'S NEW YORK BRANCH AND THROUGH UNAFFILIATED US FINANCIAL INSTITUTIONS INVOLVING PARTIES SUBJECT TO OFAC SANCTIONS THAT DID NOT CONTAIN RELEVANT INFORMATION WITHIN THE PAYMENT MESSAGES NECESSARY FOR THE US FINANCIAL INSTITUTIONS TO DETERMINE WHETHER THESE TRANSACTIONS WERE CARRIED OUT IN A MANNER CONSISTENT WITH US LAWS, WHICH RESULTED IN VIOLATIONS OF OFAC REGULATIONS. SG AGREED TO PAY A PENALTY OF $81,265,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CEASE AND DESIST ORDER IS AVAILABLE ON THE WEBSITE OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA), WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTRY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH OFAC (WITH A PENALTY OF $53.9 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE ) ( ) DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION). 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Order 11. Resolution Date (MM/DD/YYYY): 11/19/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: CIVIL MONETARY PENALTY, AS DESCRIBED BELOW. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SG AGREED TO PAY A PENALTY OF $81,265,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CEASE AND DESIST ORDER IS AVAILABLE ON THE WEBSITE OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA), WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTRY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH OFAC (WITH A PENALTY OF $53.9 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION). 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ON NOVEMBER 19, 2018, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ISSUED A CONSENTED-TO ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF CIVIL MONETARY PENALTY AGAINST SOCIÉTÉ GÉNÉRALE (SG) WITH RESPECT TO THE FOLLOWING: (1) A LACK OF ADEQUATE TRANSPARENCY, RISK MANAGEMENT, AND LEGAL AND COMPLIANCE REVIEW POLICIES AND PROCEDURES TO ENSURE THAT ACTIVITIES CONDUCTED AT SG'S OFFICES OUTSIDE OF THE UNITED STATES, PRIMARILY THROUGH THE SG'S CORPORATE AND INVESTMENT BANKING OPERATIONS, COMPILED WITH APPLICABLE REGULATIONS OF THE U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL (OFAC); AND (2) FROM AT LEAST 2007 TO 2012, AMONG OTHER THINGS, CERTAIN NON-US OFFICES, PRINCIPALLY SG IN FRANCE PROCESSED US DOLLAR DENOMINATED FUNDS TRANSFERS THROUGH THE SG'S NEW YORK BRANCH AND THROUGH UNAFFILIATED US FINANCIAL INSTITUTIONS INVOLVING PARTIES SUBJECT TO OFAC SANCTIONS THAT DID NOT CONTAIN RELEVANT INFORMATION WITHIN THE PAYMENT MESSAGES NECESSARY FOR THE US FINANCIAL INSTITUTIONS TO DETERMINE WHETHER THESE TRANSACTIONS WERE CARRIED OUT IN A MANNER CONSISTENT WITH US LAWS, WHICH RESULTED IN VIOLATIONS OF OFAC REGULATIONS. SG AGREED TO PAY A PENALTY OF $81,265,000 AND TO UNDERTAKE CERTAIN SPECIFIED REMEDIAL ACTIONS. A COPY OF THE CEASE AND DESIST ORDER IS AVAILABLE ON THE WEBSITE OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. SG ALSO ENTERED INTO CERTAIN RELATED SETTLEMENT AGREEMENTS INCLUDING A DEFERRED PROSECUTION AGREEMENT (DPA), WITH THE US DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTRY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), A SETTLEMENT AGREEMENT WITH OFAC (WITH A PENALTY OF $53.9 MILLION), AND A CONSENT ORDER ISSUED BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (WITH A PENALTY OF $325 MILLION).
regulatory · block 13SOCIÉTÉ GÉNÉRALE S.A.PDF pages 52–54
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE FOR MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS ON APRIL 29, 2016. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE SUBJECT TO CERTAIN DAILY MAXIMUMS.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ICE CLEAR CREDIT LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
04/29/2016
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2016-404B-006
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
CREDIT DEFAULT SWAP
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE FOR MISSED END OF DAY CREDIT DEFAULT SWAP
PRICING SUBMISSIONS ON APRIL 29, 2016. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE
CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A
"PER MISSED PRICE" SCHEDULE SUBJECT TO CERTAIN DAILY MAXIMUMS.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
04/29/2016
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 10,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR
MISSED SUBMISSIONS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED
SUBMISSIONS.regulatory · block 14SOCIÉTÉ GÉNÉRALE S.A.PDF pages 54–56
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- COMMISSION BANCAIRE (FRANCE)
- Monetary/Fine Amount — filed text
- $ 6,000,000.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
THE AMOUNT OF THE FINE WAS EURO 4 MILLION. THE 6 MILLION REFLECTED ABOVE IS THE APPROXIMATE VALUE OF THE FINE IN UNITED STATES DOLLARS AT THE TIME.
Other filed details
Description of allegations — filed text
FOLLOWING THE ANNOUNCEMENT ON JANUARY 24, 2008 BY SOCIÉTÉ GÉNÉRALE OF SIGNIFICANT LOSSES FROM CERTAIN UNAUTHORIZED TRADING ACTIVITY IN ITS PARIS OFFICE, THE FRENCH COMMISSION BANCAIRE REPRIMANDED AND FINED SOCIÉTÉ GÉNÉRALE EURO 4 MILLION FOR BREACHING REGULATORY PROVISIONS CONCERNING INTERNAL CONTROL PROCEDURES (FRENCH BANKING AND REGULATORY COMMITTEE REGULATION NO. 97-02).
Sanction detail — filed text
THE AMOUNT OF THE FINE WAS EURO 4 MILLION. THE 6 MILLION REFLECTED ABOVE IS THE APPROXIMATE VALUE OF THE FINE IN UNITED STATES DOLLARS AT THE TIME.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) COMMISSION BANCAIRE (FRANCE) 2. Principal Sanction: Reprimand Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 06/20/2008 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Options Other Product Types: FUTURES, STOCKS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FOLLOWING THE ANNOUNCEMENT ON JANUARY 24, 2008 BY SOCIÉTÉ GÉNÉRALE OF SIGNIFICANT LOSSES FROM CERTAIN UNAUTHORIZED TRADING ACTIVITY IN ITS PARIS OFFICE, THE FRENCH COMMISSION BANCAIRE REPRIMANDED AND FINED SOCIÉTÉ GÉNÉRALE EURO 4 MILLION FOR BREACHING REGULATORY PROVISIONS CONCERNING INTERNAL CONTROL PROCEDURES (FRENCH BANKING AND REGULATORY COMMITTEE REGULATION NO. 97-02). 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Decision 11. Resolution Date (MM/DD/YYYY): 07/03/2008 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 6,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE AMOUNT OF THE FINE WAS EURO 4 MILLION. THE 6 MILLION REFLECTED ABOVE IS THE APPROXIMATE VALUE OF THE FINE IN UNITED STATES DOLLARS AT THE TIME. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE AMOUNT OF THE FINE WAS EURO 4 MILLION. THE 6 MILLION REFLECTED ABOVE IS THE APPROXIMATE VALUE OF THE FINE IN UNITED STATES DOLLARS AT THE TIME.
regulatory · block 15SOCIÉTÉ GÉNÉRALE S.A.PDF pages 56–58
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- COMMODITY FUTURES TRADING COMMISSION (CFTC)
- Monetary/Fine Amount — filed text
- $ 75,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE RESPONDENTS ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGE THEIR CONDUCT VIOLATED THE ACT AND REGULATIONS AND CONSENTED TO: (A) THE ENTRY OF THE CFTC'S FINDINGS; (B) HAVE SOCIÉTÉ GÉNÉRALE CEASE AND DESIST FROM VIOLATION SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE ACT AND REGULATIONS 1.31, 23.201(A), 23.202(A)(1), AND (B)(1) AND 23.602(A), AND TO HAVE SGAS CEASE AND DESIST FROM VIOLATION SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35, AND 1.66.3, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $75,000,000, AND (D) COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.
Other filed details
Description of allegations — filed text
THE CFTC ENTERED INTO A SETTLEMENT ORDER ("ORDER") WITH SG AMERICAS SECURITIES LLC ("SGAS") AND SOCIÉTÉ GÉNÉRALE S.A. ("SOCIÉTÉ GÉNÉRALE" AND COLLECTIVELY, WITH SGAS THE "RESPONDENTS") TO SETTLE AN ADMINISTRATIVE ACTION CONCERNING (A) SOCIÉTÉ GÉNÉRALE'S FAILURE TO MAINTAIN REQUIRED RECORDS IN VIOLATION OF SECTION 4S(F)(1)(C) AND 4(S)(G)(1) AND (3) OF THE COMMODITY EXCHANGE ACT ("ACT") AND REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1); (B) SGAS'S FAILURE TO KEEP REQUIRED RECORDS IN VIOLATION OF SECTION 4G OF THE ACT AND REGULATION 1.35; (C) RESPONDENTS' FAILURE TO KEEP RECORDS IN THE REQUIRED MANNER IN VIOLATIONS OF REGULATION 1.31; (D) SOCIÉTÉ GÉNÉRALE'S FAILURE TO SUPERVISE DILIGENTLY IN VIOLATION OF SECTIONS 4S(H)(1)(B) OF THE ACT AND REGULATION 23.602(A); AND (E) SGAS'S FAILURE TO DILIGENTLY SUPERVISE IN VIOLATION OF REGULATION 166.3.
Sanction detail — filed text
THE RESPONDENTS ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGE THEIR CONDUCT VIOLATED THE ACT AND REGULATIONS AND CONSENTED TO: (A) THE ENTRY OF THE CFTC'S FINDINGS; (B) HAVE SOCIÉTÉ GÉNÉRALE CEASE AND DESIST FROM VIOLATION SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE ACT AND REGULATIONS 1.31, 23.201(A), 23.202(A)(1), AND (B)(1) AND 23.602(A), AND TO HAVE SGAS CEASE AND DESIST FROM VIOLATION SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35, AND 1.66.3, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $75,000,000, AND (D) COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
COMMODITY FUTURES TRADING COMMISSION (CFTC)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
08/08/2023
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
DOCKET NO. 23-35
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CFTC ENTERED INTO A SETTLEMENT ORDER ("ORDER") WITH SG AMERICAS SECURITIES LLC ("SGAS") AND SOCIÉTÉ GÉNÉRALE S.A. ("SOCIÉTÉ
GÉNÉRALE" AND COLLECTIVELY, WITH SGAS THE "RESPONDENTS") TO SETTLE AN ADMINISTRATIVE ACTION CONCERNING (A) SOCIÉTÉ GÉNÉRALE'S
FAILURE TO MAINTAIN REQUIRED RECORDS IN VIOLATION OF SECTION 4S(F)(1)(C) AND 4(S)(G)(1) AND (3) OF THE COMMODITY EXCHANGE ACT ("ACT")
AND REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1); (B) SGAS'S FAILURE TO KEEP REQUIRED RECORDS IN VIOLATION OF SECTION 4G OF THE
ACT AND REGULATION 1.35; (C) RESPONDENTS' FAILURE TO KEEP RECORDS IN THE REQUIRED MANNER IN VIOLATIONS OF REGULATION 1.31; (D)
SOCIÉTÉ GÉNÉRALE'S FAILURE TO SUPERVISE DILIGENTLY IN VIOLATION OF SECTIONS 4S(H)(1)(B) OF THE ACT AND REGULATION 23.602(A); AND (E)
SGAS'S FAILURE TO DILIGENTLY SUPERVISE IN VIOLATION OF REGULATION 166.3.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
08/08/2023
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 75,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE RESPONDENTS ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGE THEIR CONDUCT VIOLATED THE ACT AND
REGULATIONS AND CONSENTED TO: (A) THE ENTRY OF THE CFTC'S FINDINGS; (B) HAVE SOCIÉTÉ GÉNÉRALE CEASE AND DESIST FROM VIOLATION
SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE ACT AND REGULATIONS 1.31, 23.201(A), 23.202(A)(1), AND (B)(1) AND
23.602(A), AND TO HAVE SGAS CEASE AND DESIST FROM VIOLATION SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35, AND 1.66.3, (C) PAY
A CIVIL MONETARY PENALTY IN THE AMOUNT OF $75,000,000, AND (D) COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS. THE CIVIL
MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE RESPONDENTS ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGE THEIR CONDUCT VIOLATED THE ACT AND REGULATIONS AND
CONSENTED TO: (A) THE ENTRY OF THE CFTC'S FINDINGS; (B) HAVE SOCIÉTÉ GÉNÉRALE CEASE AND DESIST FROM VIOLATION SECTIONS 4S(F)(1)(C),
4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE ACT AND REGULATIONS 1.31, 23.201(A), 23.202(A)(1), AND (B)(1) AND 23.602(A), AND TO HAVE SGAS
CEASE AND DESIST FROM VIOLATION SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35, AND 1.66.3, (C) PAY A CIVIL MONETARY PENALTY IN THE
AMOUNT OF $75,000,000, AND (D) COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS. THE CIVIL MONETARY PENALTY WAS PAID IN
ACCORDANCE WITH THE TERMS OF THE ORDER.regulatory · block 16SOCIÉTÉ GÉNÉRALE S.A.PDF pages 58–60
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 129,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $129,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $129,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS ON NOVEMBER 27, 2015. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $129,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ICE CLEAR CREDIT LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
01/25/2016
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2016-404B-046
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
CREDIT DEFAULT SWAP
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $129,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR MISSED END OF DAY CREDIT DEFAULT SWAP
PRICING SUBMISSIONS ON NOVEMBER 27, 2015. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS
UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
01/25/2016
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 129,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ICE CLEAR ISSUED AN ASSESSMENT OF $129,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR
MISSED SUBMISSIONS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ICE CLEAR ISSUED AN ASSESSMENT OF $129,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR
MISSED SUBMISSIONS.regulatory · block 17SOCIÉTÉ GÉNÉRALE S.A.PDF pages 60–62
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
- Monetary/Fine Amount — filed text
- $ 95,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON NOVEMBER 19, 2018 SOCIÉTÉ GÉNÉRALE (SG) AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (SGNY) (COLLECTIVELY "SG"), AGREED TO THE ENTRY OF A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES TO RESOLVE AN ENFORCEMENT ACTION BASED ON THE NYDFS'S FINDING THAT SERIOUS DEFICIENCIES EXISTED IN THE BSA/AML COMPLIANCE PROGRAM AT THE SGNY OVER SEVERAL EXAM CYCLES FROM 2014 FORWARD. THE NYDFS CONSENT ORDER DESCRIBED SEVERAL DEFICIENCIES, INCLUDING ONES RELATED TO BSA/AML COMPLIANCE PROGRAM GOVERNANCE AND OVERSIGHT, RISK ASSESSMENT, AND TRANSACTION MONITORING, AND CITED VIOLATIONS OF NEW YORK BANKING LAW AND A 2009 WRITTEN AGREEMENT BETWEEN SG AND SGNY AND THE NYDFS (AND THE FEDERAL RESERVE). THE CONSENT ORDER INCLUDED A PENALTY OF $95,000,000 AND MULTIPLE REMEDIAL OBLIGATIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE IN THE NYDFS WEBSITE.
Other filed details
Description of allegations — filed text
ON NOVEMBER 19, 2018 SOCIÉTÉ GÉNÉRALE (SG) AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (SGNY) COLLECTIVELY ("SG"), AGREED TO THE ENTRY OF A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("NYDFS") TO RESOLVE AN ENFORCEMENT ACTION BASED ON NYDFS'S FINDINGS THAT SERIOUS DEFICIENCIES EXISTED IN THE ANTI-MONEY LAUNDERING/BANK SECRECY ACT (BSA/AML) COMPLIANCE PROGRAM AT THE SGNY OVER SEVERAL EXAM CYCLES FROM 2014 FORWARD. THE NYDFS'S CONSENT ORDER DESCRIBED SEVERAL DEFICIENCIES, INCLUDING ONES RELATED TO BSA/AML COMPLIANCE PROGRAM GOVERNANCE AND OVERSIGHT, RISK ASSESSMENT, AND TRANSACTION MONITORING, AND CITED VIOLATIONS OF NEW YORK BANKING LAW AND A 2009 WRITTEN AGREEMENT BETWEEN SG AND SGNY AND THE NYDFS (AND THE FEDERAL RESERVE). THE CONSENT ORDER INCLUDED A PENALTY OF $95,000,000 AND MULTIPLE REMEDIAL OBLIGATIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE ON THE NYDFS WEBSITE.
Sanction detail — filed text
THE CONSENT ORDER INCLUDED A PENALTY OF $95,000,000 AND MULTIPLE REMEDIAL OBLIGATIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE IN THE NYDFS WEBSITE.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
11/19/2018
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON NOVEMBER 19, 2018 SOCIÉTÉ GÉNÉRALE (SG) AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (SGNY) COLLECTIVELY ("SG"), AGREED TO THE ENTRY
OF A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("NYDFS") TO RESOLVE AN ENFORCEMENT ACTION BASED
ON NYDFS'S FINDINGS THAT SERIOUS DEFICIENCIES EXISTED IN THE ANTI-MONEY LAUNDERING/BANK SECRECY ACT (BSA/AML) COMPLIANCE PROGRAM
AT THE SGNY OVER SEVERAL EXAM CYCLES FROM 2014 FORWARD. THE NYDFS'S CONSENT ORDER DESCRIBED SEVERAL DEFICIENCIES, INCLUDING
ONES RELATED TO BSA/AML COMPLIANCE PROGRAM GOVERNANCE AND OVERSIGHT, RISK ASSESSMENT, AND TRANSACTION MONITORING, AND CITED
VIOLATIONS OF NEW YORK BANKING LAW AND A 2009 WRITTEN AGREEMENT BETWEEN SG AND SGNY AND THE NYDFS (AND THE FEDERAL RESERVE).
THE CONSENT ORDER INCLUDED A PENALTY OF $95,000,000 AND MULTIPLE REMEDIAL OBLIGATIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE
ON THE NYDFS WEBSITE.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
11/19/2018
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 95,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE CONSENT ORDER INCLUDED A PENALTY OF $95,000,000 AND MULTIPLE REMEDIAL OBLIGATIONS. A COPY OF THE CONSENT ORDER IS
AVAILABLE IN THE NYDFS WEBSITE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON NOVEMBER 19, 2018 SOCIÉTÉ GÉNÉRALE (SG) AND SOCIÉTÉ GÉNÉRALE NEW YORK BRANCH (SGNY) (COLLECTIVELY "SG"), AGREED TO THE ENTRY
OF A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES TO RESOLVE AN ENFORCEMENT ACTION BASED ON THE
NYDFS'S FINDING THAT SERIOUS DEFICIENCIES EXISTED IN THE BSA/AML COMPLIANCE PROGRAM AT THE SGNY OVER SEVERAL EXAM CYCLES FROM
2014 FORWARD. THE NYDFS CONSENT ORDER DESCRIBED SEVERAL DEFICIENCIES, INCLUDING ONES RELATED TO BSA/AML COMPLIANCE PROGRAM
GOVERNANCE AND OVERSIGHT, RISK ASSESSMENT, AND TRANSACTION MONITORING, AND CITED VIOLATIONS OF NEW YORK BANKING LAW AND A 2009
WRITTEN AGREEMENT BETWEEN SG AND SGNY AND THE NYDFS (AND THE FEDERAL RESERVE). THE CONSENT ORDER INCLUDED A PENALTY OF
$95,000,000 AND MULTIPLE REMEDIAL OBLIGATIONS. A COPY OF THE CONSENT ORDER IS AVAILABLE IN THE NYDFS WEBSITE.regulatory · block 18SOCIÉTÉ GÉNÉRALE S.A.PDF pages 62–64
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC (ICE CLEAR) ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN JUNE 2018. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON FEBRUARY 4, 2019 AFTER SG DETERMINED NOT TO SEEK WAIVER.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) ICE CLEAR CREDIT LLC 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 01/10/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018-404B-028 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: CREDIT DEFAULT SWAP 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ICE CLEAR CREDIT LLC (ICE CLEAR) ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN JUNE 2018. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON FEBRUARY 4, 2019 AFTER SG DETERMINED NOT TO SEEK WAIVER. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Other 11. Resolution Date (MM/DD/YYYY): 02/04/2019 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 10,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
regulatory · block 19SOCIÉTÉ GÉNÉRALE S.A.PDF pages 64–66
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 110,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $110,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC (ICE CLEAR) ISSUED A $110,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN JUNE 2018. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON JULY 25, 2018, AFTER SG DETERMINED NOT TO SEEK A WAIVER.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $110,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) ICE CLEAR CREDIT LLC 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/10/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018-404B-008 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: CREDIT DEFAULT SWAP 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ICE CLEAR CREDIT LLC (ICE CLEAR) ISSUED A $110,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN JUNE 2018. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON JULY 25, 2018, AFTER SG DETERMINED NOT TO SEEK A WAIVER. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Other 11. Resolution Date (MM/DD/YYYY): 07/25/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 110,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ICE CLEAR ISSUED AN ASSESSMENT OF $110,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ICE CLEAR ISSUED AN ASSESSMENT OF $110,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
regulatory · block 20SOCIÉTÉ GÉNÉRALE S.A.PDF pages 66–67
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- COMMODITY FUTURES TRADING COMMISSION
- Monetary/Fine Amount — filed text
- $ 475,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE FIRM WAS, UNDER THE ORDER, REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $475,000,000. SG WIRED THIS PAYMENT ON JUNE 13, 2018 AND THE CFTC CONFIRMED RECEIPT AS ON JUNE 14, 2018.
Other filed details
Description of allegations — filed text
ON JUNE 4, 2018, THE COMMODITY FUTURES TRADING COMMISSION (CFTC) ENTERED AN ORDER (THE "ORDER") INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C) AND 5(D) OF THE COMMODITY EXCHANGE ACT (THE "CEA"), FINDING THAT, DURING THE PERIOD OF 2006 THROUGH MID- 2012, SOCIÉTÉ GÉNÉRALE (SG), BY AND THROUGH CERTAIN TRADERS AND CERTAIN MEMBERS OF MANAGEMENT, COMMITTED ACTS OF ATTEMPTED MANIPULATION AND/OR ACTUAL MANIPULATION OF, AN MADE FALSE, MISLEADING OR KNOWINGLY INACCURATE REPORTS OF MARKET INFORMATION IN CONNECTION WITH LIBOR FOR US DOLLAR, YEN. AND THE EURO AND THE EURO INTERBANK OFFERED RATE (EURIBOR) IN VIOLATION OF SECTIONS 6(C) AND 6(D) (FOR CONDUCT OCCURRING PRIOR TO AUGUST 15, 2011) AND SECTION 9(A)(2) OF THE CEA.
Sanction detail — filed text
THE FIRM WAS, UNDER THE ORDER, REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $475,000,000. SG WIRED THIS PAYMENT ON JUNE 13, 2018 AND THE CFTC CONFIRMED RECEIPT AS ON JUNE 14, 2018.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) COMMODITY FUTURES TRADING COMMISSION 2. Principal Sanction: Cease and Desist Other Sanctions: UNDERTAKING, MONETARY FINE 3. Date Initiated (MM/DD/YYYY): 06/04/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CFTC DOCKET NO. 18-14 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Futures - Financial Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON JUNE 4, 2018, THE COMMODITY FUTURES TRADING COMMISSION (CFTC) ENTERED AN ORDER (THE "ORDER") INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C) AND 5(D) OF THE COMMODITY EXCHANGE ACT (THE "CEA"), FINDING THAT, DURING THE PERIOD OF 2006 THROUGH MID- 2012, SOCIÉTÉ GÉNÉRALE (SG), BY AND THROUGH CERTAIN TRADERS AND CERTAIN MEMBERS OF MANAGEMENT, COMMITTED ACTS OF ATTEMPTED MANIPULATION AND/OR ACTUAL MANIPULATION OF, AN MADE FALSE, MISLEADING OR KNOWINGLY INACCURATE REPORTS OF MARKET INFORMATION IN CONNECTION WITH LIBOR FOR US DOLLAR, YEN. AND THE EURO AND THE EURO INTERBANK OFFERED RATE (EURIBOR) IN VIOLATION OF SECTIONS 6(C) AND 6(D) (FOR CONDUCT OCCURRING PRIOR TO AUGUST 15, 2011) AND SECTION 9(A)(2) OF THE CEA. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Order 11. Resolution Date (MM/DD/YYYY): 06/04/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 475,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS, UNDER THE ORDER, REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $475,000,000. SG WIRED THIS PAYMENT ON JUNE 13, 2018 AND THE CFTC CONFIRMED RECEIPT AS ON JUNE 14, 2018. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE FIRM WAS, UNDER THE ORDER, REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $475,000,000. SG WIRED THIS PAYMENT ON JUNE 13, 2018 AND THE CFTC CONFIRMED RECEIPT AS ON JUNE 14, 2018.
regulatory · block 21SOCIÉTÉ GÉNÉRALE S.A.PDF pages 67–69
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR NINE MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN MARCH 2017. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON APRIL 20, 2017, AFTER SG DETERMINED NOT TO SEEK WAIVER.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ICE CLEAR CREDIT LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
04/20/2017
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2017-404B-004
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
CREDIT DEFAULT SWAP
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR NINE MISSED END OF DAY CREDIT DEFAULT
SWAP PRICING SUBMISSIONS IN MARCH 2017. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER
ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO
CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON APRIL 20, 2017, AFTER SG DETERMINED NOT TO SEEK WAIVER.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
04/20/2017
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 10,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR
MISSED SUBMISSIONS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED
SUBMISSIONS.regulatory · block 22SOCIÉTÉ GÉNÉRALE S.A.PDF pages 69–71
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR NINE MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN APRIL 2017. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON MAY 17, 2017, AFTER SG DETERMINED NOT TO SEEK WAIVER.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ICE CLEAR CREDIT LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
05/17/2017
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2017-404B-005
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
CREDIT DEFAULT SWAP
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR NINE MISSED END OF DAY CREDIT DEFAULT
SWAP PRICING SUBMISSIONS IN APRIL 2017. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER
ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO
CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON MAY 17, 2017, AFTER SG DETERMINED NOT TO SEEK WAIVER.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
05/17/2017
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 10,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR
MISSED SUBMISSIONS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED
SUBMISSIONS.regulatory · block 23SOCIÉTÉ GÉNÉRALE S.A.PDF pages 71–73
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC (ICE CLEAR) ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR NINE MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN DECEMBER 2016. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL WHEN SG DETERMINED NOT TO SEEK A WAIVER ON FEBRUARY 3, 2017.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) ICE CLEAR CREDIT LLC 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 04/20/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2016-404B-044 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: CREDIT DEFAULT SWAP 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ICE CLEAR CREDIT LLC (ICE CLEAR) ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR NINE MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN DECEMBER 2016. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL WHEN SG DETERMINED NOT TO SEEK A WAIVER ON FEBRUARY 3, 2017. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Other 11. Resolution Date (MM/DD/YYYY): 02/03/2017 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 10,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ICE CLEAR ISSUED AN ASSESSMENT OF $10,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
regulatory · block 24SOCIÉTÉ GÉNÉRALE S.A.PDF pages 73–75
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- COMMODITY FUTURES TRADING COMMISSION
- Monetary/Fine Amount — filed text
- $ 450,000.00
- How was matter resolved — filed text
- Decision & Order of Offer of Settlement
Action status / disposition — filed text
SG AGREED TO A FINE OF $450,000 AND WAS ORDERED TO CEASE AND DESIST FROM FUTURE VIOLATIONS.
Other filed details
Description of allegations — filed text
THE COMMISSION FOUND THAT SOCIÉTÉ GÉNÉRALE (SG) INADVERTENTLY FAILED TO REPORT TO SWAP DATA DEPOSITORY CERTAIN NONDELIVERABLE FORWARDS, FX SWAP, AND FX FORWARD TRANSACTIONS BETWEEN JULY 2014 AND APRIL 2015. AS A RESULT, THE CFTC FOUND THAT SG VIOLATED SECTIONS 2(A)(13)(F) AND (G) AND 4(R)(3) OF THE ACT, 7 USC SEC. 2(A)(13)(F) AND (G) (2012), AND REGULATIONS 43.3(A)(3), 43(A), 45.3(C)(1) AND 45.4(A), 17 CFR SEC. 43. 3(A)(3), 43.4(A), 45.4(C)(1) AND 45.4(A)(2016).
Sanction detail — filed text
SG AGREED TO A FINE OF $450,000 AND WAS ORDERED TO CEASE AND DESIST FROM FUTURE VIOLATIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) COMMODITY FUTURES TRADING COMMISSION 2. Principal Sanction: Cease and Desist Other Sanctions: CIVIL MONETARY PENALTY 3. Date Initiated (MM/DD/YYYY): 12/07/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CFTC DOCKET NO. 17-01 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: FX SWAPS, FX FORWARDS, AND NON-DELIVERABLE FORWARDS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE COMMISSION FOUND THAT SOCIÉTÉ GÉNÉRALE (SG) INADVERTENTLY FAILED TO REPORT TO SWAP DATA DEPOSITORY CERTAIN NONDELIVERABLE FORWARDS, FX SWAP, AND FX FORWARD TRANSACTIONS BETWEEN JULY 2014 AND APRIL 2015. AS A RESULT, THE CFTC FOUND THAT SG VIOLATED SECTIONS 2(A)(13)(F) AND (G) AND 4(R)(3) OF THE ACT, 7 USC SEC. 2(A)(13)(F) AND (G) (2012), AND REGULATIONS 43.3(A)(3), 43(A), 45.3(C)(1) AND 45.4(A), 17 CFR SEC. 43. 3(A)(3), 43.4(A), 45.4(C)(1) AND 45.4(A)(2016). 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Decision & Order of Offer of Settlement 11. Resolution Date (MM/DD/YYYY): 12/07/2016 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 450,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SG AGREED TO A FINE OF $450,000 AND WAS ORDERED TO CEASE AND DESIST FROM FUTURE VIOLATIONS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SG AGREED TO A FINE OF $450,000 AND WAS ORDERED TO CEASE AND DESIST FROM FUTURE VIOLATIONS.
regulatory · block 25SOCIÉTÉ GÉNÉRALE S.A.PDF pages 75–77
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- AUTORITE DES MARCHES FINANCIERS (AMF)
- Monetary/Fine Amount — filed text
- $ 526,410.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
IN TERMS OF THIS SETTLEMENT, THE BANK UNDERTOOK TO PAY THE PUBLIC TREASURY 450,000 EUROS EQUAL TO $526,410 US DOLLARS, CARRY OUT REGULAR CHECKS ON ITS INVESTMENT RESEARCH AND FINANCIAL ANALYSIS ACTIVITY, ENSURING THAT FORMALITIES ARE COMPLETED AND THAT THE COMPLIANCE DEPARTMENT HAS ACCESS TO RELEVANT INFORMATION, AND BY CARRYING OUT SECOND-LEVEL CHECKS IN ORDER TO IDENTIFY POSSIBLE FAILINGS, BOLSTER ITS AUDIT PLAN IN THE DEPARTMENT IN QUESTIONS, STRENGTHEN ITS PROCESSES FOR MANAGING INSIDE INFORMATION IN THE CONTEXT OF THE ACTIVITY INVOLVED IN THE AUDIT, APPOINT, AT ITS OWN EXPENSE, AN EXTERNAL AUDIT FIRM TO CARRY OUT AN AUDIT ON THE PROPER IMPLEMENTATION OF THE UNDERTAKINGS MADE AND WHICH MUST BE SENT TO THE AMF WITHIN SIX MONTHS OF APPROVAL OF THE SETTLEMENT AGREEMENT BY THE SANCTIONS COMMITTEE.
Other filed details
Description of allegations — filed text
SOCIÉTÉ GÉNÉRALE (SG) ENTERED INTO A SETTLEMENT AGREEMENT WITH THE AMF FOLLOWING AN AUDIT REGARDING ITS INDEPENDENT RESEARCH AND FINANCIAL ANALYSIS ACTIVITIES. THE AMF NOTED THAT SG DID NOT FULLY COMPLY WITH THE PROVISIONS COVERING THE PRODUCTION OF ANALYST NOTES, AND MORE SPECIFICALLY THEIR CONTENT AND THE CONTROL THEREOF BY THE COMPLIANCE DEPARTMENT. THE SETTLEMENT ALSO HIGHLIGHTED ISSUES RELATING TO COMPLIANCE WITH AMF PROVISIONS COVERING THE MANAGEMENT OF INSIDE INFORMATION.
Sanction detail — filed text
IN TERMS OF THIS SETTLEMENT, THE BANK UNDERTOOK TO PAY THE PUBLIC TREASURY 450,000 EUROS EQUAL TO $526,410 US DOLLARS, CARRY OUT REGULAR CHECKS ON ITS INVESTMENT RESEARCH AND FINANCIAL ANALYSIS ACTIVITY, ENSURING THAT FORMALITIES ARE COMPLETED AND THAT THE COMPLIANCE DEPARTMENT HAS ACCESS TO RELEVANT INFORMATION, AND BY CARRYING OUT SECOND-LEVEL CHECKS IN ORDER TO IDENTIFY POSSIBLE FAILINGS, BOLSTER ITS AUDIT PLAN IN THE DEPARTMENT IN QUESTIONS, STRENGTHEN ITS PROCESSES FOR MANAGING INSIDE INFORMATION IN THE CONTEXT OF THE ACTIVITY INVOLVED IN THE AUDIT, APPOINT, AT ITS OWN EXPENSE, AN EXTERNAL AUDIT FIRM TO CARRY OUT AN AUDIT ON THE PROPER IMPLEMENTATION OF THE UNDERTAKINGS MADE AND WHICH MUST BE SENT TO THE AMF WITHIN SIX MONTHS OF APPROVAL OF THE SETTLEMENT AGREEMENT BY THE SANCTIONS COMMITTEE.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) AUTORITE DES MARCHES FINANCIERS (AMF) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 03/20/2015 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: INVESTMENT RESEARCH AND FINANCIAL ANALYSIS ACTIVITY 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): SOCIÉTÉ GÉNÉRALE (SG) ENTERED INTO A SETTLEMENT AGREEMENT WITH THE AMF FOLLOWING AN AUDIT REGARDING ITS INDEPENDENT RESEARCH AND FINANCIAL ANALYSIS ACTIVITIES. THE AMF NOTED THAT SG DID NOT FULLY COMPLY WITH THE PROVISIONS COVERING THE PRODUCTION OF ANALYST NOTES, AND MORE SPECIFICALLY THEIR CONTENT AND THE CONTROL THEREOF BY THE COMPLIANCE DEPARTMENT. THE SETTLEMENT ALSO HIGHLIGHTED ISSUES RELATING TO COMPLIANCE WITH AMF PROVISIONS COVERING THE MANAGEMENT OF INSIDE INFORMATION. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Settled 11. Resolution Date (MM/DD/YYYY): 06/23/2017 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 526,410.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: IN TERMS OF THIS SETTLEMENT, THE BANK UNDERTOOK TO PAY THE PUBLIC TREASURY 450,000 EUROS EQUAL TO $526,410 US DOLLARS, CARRY OUT REGULAR CHECKS ON ITS INVESTMENT RESEARCH AND FINANCIAL ANALYSIS ACTIVITY, ENSURING THAT FORMALITIES ARE COMPLETED AND THAT THE COMPLIANCE DEPARTMENT HAS ACCESS TO RELEVANT INFORMATION, AND BY CARRYING OUT SECOND-LEVEL CHECKS IN ORDER TO IDENTIFY POSSIBLE FAILINGS, BOLSTER ITS AUDIT PLAN IN THE DEPARTMENT IN QUESTIONS, STRENGTHEN ITS PROCESSES FOR MANAGING INSIDE INFORMATION IN THE CONTEXT OF THE ACTIVITY INVOLVED IN THE AUDIT, APPOINT, AT ITS OWN EXPENSE, AN EXTERNAL AUDIT FIRM TO CARRY OUT AN AUDIT ON THE PROPER IMPLEMENTATION OF THE UNDERTAKINGS MADE AND WHICH MUST BE SENT TO THE AMF WITHIN SIX MONTHS OF APPROVAL OF THE SETTLEMENT AGREEMENT BY THE SANCTIONS COMMITTEE. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). IN TERMS OF THIS SETTLEMENT, THE BANK UNDERTOOK TO PAY THE PUBLIC TREASURY 450,000 EUROS EQUAL TO $526,410 US DOLLARS, CARRY OUT REGULAR CHECKS ON ITS INVESTMENT RESEARCH AND FINANCIAL ANALYSIS ACTIVITY, ENSURING THAT FORMALITIES ARE COMPLETED AND THAT THE COMPLIANCE DEPARTMENT HAS ACCESS TO RELEVANT INFORMATION, AND BY CARRYING OUT SECOND-LEVEL CHECKS IN ORDER TO IDENTIFY POSSIBLE FAILINGS, BOLSTER ITS AUDIT PLAN IN THE DEPARTMENT IN QUESTIONS, STRENGTHEN ITS PROCESSES FOR MANAGING INSIDE INFORMATION IN THE CONTEXT OF THE ACTIVITY INVOLVED IN THE AUDIT, APPOINT, AT ITS OWN EXPENSE, AN EXTERNAL AUDIT FIRM TO CARRY OUT AN AUDIT ON THE PROPER IMPLEMENTATION OF THE UNDERTAKINGS MADE AND WHICH MUST BE SENT TO THE AMF WITHIN SIX MONTHS OF APPROVAL OF THE SETTLEMENT AGREEMENT BY THE SANCTIONS COMMITTEE.
regulatory · block 26SOCIÉTÉ GÉNÉRALE S.A.PDF pages 77–79
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LLC (ICE CLEAR) ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR 18 MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN FEBRUARY 2018. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON MARCH 30, 2018, AFTER SG DETERMINED NOT TO SEEK A WAIVER.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) ICE CLEAR CREDIT LLC 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 03/02/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018-404B-008 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: CREDIT DEFAULT SWAP 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ICE CLEAR CREDIT LLC (ICE CLEAR) ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR 18 MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN FEBRUARY 2018. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON MARCH 30, 2018, AFTER SG DETERMINED NOT TO SEEK A WAIVER. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Other 11. Resolution Date (MM/DD/YYYY): 03/30/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 10,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
regulatory · block 27SOCIÉTÉ GÉNÉRALE S.A.PDF pages 79–81
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- FRENCH PRUDENTIAL SUPERVISION AND RESOLUTION AUTHORITY (ACPR)
- Monetary/Fine Amount — filed text
- $ 5,757,500.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
THE ACPR ENFORCEMENT COMMISSION ISSUED A REPRIMAND AGAINST SG AND ORDERED IT TO PAY A FINE OF EUR 5 MILLION ($5,757,500 ACCORDING TO THE EXCHANGE RATE ON 7/19/2017).
Other filed details
Description of allegations — filed text
THE ACPR, IN CHARGE OF OVERSEEING THE FRENCH BANKING AND INSURANCE SECTORS, CONDUCTED ON AN ONSITE EXAMINATION FROM SEPTEMBER 8 TO DECEMBER 1, 2015 REGARDING SOCIÉTÉ GÉNÉRALE'S (SG) PROCEDURES FOR SUSPICIOUS ACTIVITY REPORTING (SAR). ON JUNE 5, 2016, THE ACPR INITIATED A DISCIPLINARY PROCEDURE AGAINST SG. THE ACPR ENFORCEMENT DECISION DELIVERED ITS DECISION ON JULY 19, 2017, WHICH INCLUDED A REPRIMAND AND A 5 MILLION EURO FINE. THE DECISION, WHICH IS AVAILABLE ON THE ACPR'S WEBSITE, FOUND THAT THE SAR PROCEDURES IMPLEMENTED BY SG WERE INADEQUATE IN CERTAIN RESPECTS TO ENABLE SG TO PROPERLY COMPLY WITH ITS OBLIGATION TO TIMELY REPORT SUSPICIOUS TRANSACTIONS "WITHOUT DELAY" TO TRACFIN, THE FRENCH FINANCIAL INVESTIGATIONS UNIT, AS REQUIRED UNDER THE LAW; FOUND CERTAIN OTHER WEAKNESSES IN SG'S PROCEDURES AND CONTROLS AROUND DETECTING AND ANALYZING UNUSUAL TRANSACTIONS AND COMPLYING WITH ITS REPORTING OBLIGATIONS; AND FOUND THAT SG HAD INCORRECTLY REPORTED ITS PROCESSING TIMES FOR SARS TO TRACFIN.
Sanction detail — filed text
THE ACPR ENFORCEMENT COMMISSION ISSUED A REPRIMAND AGAINST SG AND ORDERED IT TO PAY A FINE OF EUR 5 MILLION ($5,757,500 ACCORDING TO THE EXCHANGE RATE ON 7/19/2017).
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FRENCH PRUDENTIAL SUPERVISION AND RESOLUTION AUTHORITY (ACPR) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: REPRIMAND 3. Date Initiated (MM/DD/YYYY): 07/26/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE ACPR, IN CHARGE OF OVERSEEING THE FRENCH BANKING AND INSURANCE SECTORS, CONDUCTED ON AN ONSITE EXAMINATION FROM SEPTEMBER 8 TO DECEMBER 1, 2015 REGARDING SOCIÉTÉ GÉNÉRALE'S (SG) PROCEDURES FOR SUSPICIOUS ACTIVITY REPORTING (SAR). ON JUNE 5, 2016, THE ACPR INITIATED A DISCIPLINARY PROCEDURE AGAINST SG. THE ACPR ENFORCEMENT DECISION DELIVERED ITS DECISION ON JULY 19, 2017, WHICH INCLUDED A REPRIMAND AND A 5 MILLION EURO FINE. THE DECISION, WHICH IS AVAILABLE ON THE ACPR'S WEBSITE, FOUND THAT THE SAR PROCEDURES IMPLEMENTED BY SG WERE INADEQUATE IN CERTAIN RESPECTS TO ENABLE SG TO PROPERLY COMPLY WITH ITS OBLIGATION TO TIMELY REPORT SUSPICIOUS TRANSACTIONS "WITHOUT DELAY" TO TRACFIN, THE FRENCH FINANCIAL INVESTIGATIONS UNIT, AS REQUIRED UNDER THE LAW; FOUND CERTAIN OTHER WEAKNESSES IN SG'S PROCEDURES AND CONTROLS AROUND DETECTING AND ANALYZING UNUSUAL TRANSACTIONS AND COMPLYING WITH ITS REPORTING OBLIGATIONS; AND FOUND THAT SG HAD INCORRECTLY REPORTED ITS PROCESSING TIMES FOR SARS TO TRACFIN. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Decision 11. Resolution Date (MM/DD/YYYY): 07/19/2017 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 5,757,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE ACPR ENFORCEMENT COMMISSION ISSUED A REPRIMAND AGAINST SG AND ORDERED IT TO PAY A FINE OF EUR 5 MILLION ($5,757,500 ACCORDING TO THE EXCHANGE RATE ON 7/19/2017). 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE ACPR ENFORCEMENT COMMISSION ISSUED A REPRIMAND AGAINST SG AND ORDERED IT TO PAY A FINE OF EUR 5 MILLION ($5,757,500 ACCORDING TO THE EXCHANGE RATE ON 7/19/2017).
regulatory · block 28SOCIÉTÉ GÉNÉRALE S.A.PDF pages 81–82
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- CME GROUP INC.
- Monetary/Fine Amount — filed text
- $ 2,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
SUMMARY FINE FOR VARIOUS TRADE DATES FROM MARCH 2019 TO JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION.
Other filed details
Description of allegations — filed text
FOR VARIOUS TRADE DATES FROM MARCH 2019 TO JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION WERE REPORTED FOR REPORTING # 0DG02 IN VIOLATION.
Sanction detail — filed text
SUMMARY FINE FOR VARIOUS TRADE DATES FROM MARCH 2019 TO JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) CME GROUP INC. 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: SUMMARY FINE 3. Date Initiated (MM/DD/YYYY): 08/11/2021 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Futures - Commodity Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FOR VARIOUS TRADE DATES FROM MARCH 2019 TO JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION WERE REPORTED FOR REPORTING # 0DG02 IN VIOLATION. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 08/11/2021 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 2,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SUMMARY FINE FOR VARIOUS TRADE DATES FROM MARCH 2019 TO JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SUMMARY FINE FOR VARIOUS TRADE DATES FROM MARCH 2019 TO JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION.
regulatory · block 29SOCIÉTÉ GÉNÉRALE S.A.PDF pages 82–84
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE FUTURES U.S., INC.
- Monetary/Fine Amount — filed text
- $ 15,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
AT A MEETING HELD ON JUNE 7, 2023, THE BUSINESS CONDUCT COMMITTEE ("BCC") OF ICE FUTURES U.S., INC. ("IFUS" OR THE EXCHANGE) DETERMINED THAT SOCIÉTÉ GÉNÉRALE ("SG") MAY HAVE VIOLATED EXCHANGE RULES 4.02(C) BY EXECUTING TRANSACTION THAT MAY HAVE RESULTED IN AN INDIRECT WASH TRADE, AND 4.07(C) IN FOUR (4) INSTANCES BY MISREPORTING THE EXECUTION TIME OF A BLOCK TRADE AND FOUR (4) INSTANCES BY SUBMITTING SUCH BLOCK TRADE TO THE EXCHANGE BEYOND THE 15-MINUTE REPORTING WINDOW. AT THAT MEETING, THE BCC APPROVED A SETTLEMENT AGREEMENT UNDER WHICH SG AGREED TO PAY A FINE OF $15,000.
Other filed details
Description of allegations — filed text
AT A MEETING HELD ON JUNE 7, 2023, THE BUSINESS CONDUCT COMMITTEE ("BCC") OF ICE FUTURES U.S., INC. ("IFUS" OR THE EXCHANGE) DETERMINED THAT SOCIÉTÉ GÉNÉRALE ("SG") MAY HAVE VIOLATED EXCHANGE RULES 4.02(C) BY EXECUTING TRANSACTION THAT MAY HAVE RESULTED IN AN INDIRECT WASH TRADE, AND 4.07(C) IN FOUR (4) INSTANCES BY MISREPORTING THE EXECUTION TIME OF A BLOCK TRADE AND FOUR (4) INSTANCES BY SUBMITTING SUCH BLOCK TRADE TO THE EXCHANGE BEYOND THE 15-MINUTE REPORTING WINDOW. AT THAT MEETING, THE BCC APPROVED A SETTLEMENT AGREEMENT UNDER WHICH SG AGREED TO PAY A FINE OF $15,000.
Sanction detail — filed text
IFUS SETTLED THE MATTER.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIÉTÉ GÉNÉRALE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ICE FUTURES U.S., INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
04/13/2021
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2021-022
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Derivative(s)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
AT A MEETING HELD ON JUNE 7, 2023, THE BUSINESS CONDUCT COMMITTEE ("BCC") OF ICE FUTURES U.S., INC. ("IFUS" OR THE EXCHANGE)
DETERMINED THAT SOCIÉTÉ GÉNÉRALE ("SG") MAY HAVE VIOLATED EXCHANGE RULES 4.02(C) BY EXECUTING TRANSACTION THAT MAY HAVE RESULTED
IN AN INDIRECT WASH TRADE, AND 4.07(C) IN FOUR (4) INSTANCES BY MISREPORTING THE EXECUTION TIME OF A BLOCK TRADE AND FOUR (4)
INSTANCES BY SUBMITTING SUCH BLOCK TRADE TO THE EXCHANGE BEYOND THE 15-MINUTE REPORTING WINDOW. AT THAT MEETING, THE BCC
APPROVED A SETTLEMENT AGREEMENT UNDER WHICH SG AGREED TO PAY A FINE OF $15,000.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
06/07/2023
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 15,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
IFUS SETTLED THE MATTER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
AT A MEETING HELD ON JUNE 7, 2023, THE BUSINESS CONDUCT COMMITTEE ("BCC") OF ICE FUTURES U.S., INC. ("IFUS" OR THE EXCHANGE)
DETERMINED THAT SOCIÉTÉ GÉNÉRALE ("SG") MAY HAVE VIOLATED EXCHANGE RULES 4.02(C) BY EXECUTING TRANSACTION THAT MAY HAVE RESULTED
IN AN INDIRECT WASH TRADE, AND 4.07(C) IN FOUR (4) INSTANCES BY MISREPORTING THE EXECUTION TIME OF A BLOCK TRADE AND FOUR (4)
INSTANCES BY SUBMITTING SUCH BLOCK TRADE TO THE EXCHANGE BEYOND THE 15-MINUTE REPORTING WINDOW. AT THAT MEETING, THE BCC
APPROVED A SETTLEMENT AGREEMENT UNDER WHICH SG AGREED TO PAY A FINE OF $15,000.regulatory · block 30SOCIÉTÉ GÉNÉRALE S.A.PDF pages 84–86
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- THE FRENCH COMPETITION AUTHORITY
- Monetary/Fine Amount — filed text
- $ 58,870,000.00
- How was matter resolved — filed text
- Dismissed
Action status / disposition — filed text
IN THE EARLY 2000S, THE FRENCH BANKING INDUSTRY DECIDED TO TRANSITION TO A NEW DIGITAL SYSTEM IN ORDER TO STREAMLINE CHEQUE CLEARING. TO SUPPORT THIS REFORM, WHICH HAS CONTRIBUTED TO THE IMPROVEMENT OF CHEQUE PAYMENTS SECURITY AND TO THE FIGHT AGAINST FRAUD, THE BANKS ESTABLISHED SEVERAL INTERBANK FEES, INCLUDING THE CEIC WHICH WAS ABOLISHED IN 2007. THESE FEES WERE IMPLEMENTED UNDER THE AEGIS OF THE BANKING SECTOR SUPERVISORY AUTHORITIES, AND TO THE KNOWLEDGE OF THE PUBLIC AUTHORITIES. ON 20, SEPTEMBER 2010, AFTER SEVERAL YEARS OF INVESTIGATION, THE FRENCH COMPETITION AUTHORITY RULED THAT THE JOINT IMPLEMENTATION AND THE SETTING OF THE AMOUNT OF THE CEIC AND OF TWO ADDITIONAL FEES FOR RELATED SERVICES WERE IN BREACH OF COMPETITION LAW. THE AUTHORITY FINED ALL PARTICIPANTS TO THE AGREEMENT (INCLUDING THE BANQUE DU FRANCE) A TOTAL OF APPROXIMATELY EUR 53.5 MILLION. SOCIÉTÉ GÉNÉRALE WAS ORDERED TO PAY A FINE OF EUR 385 MILLION AND CREDIT DU NORD, ITS SUBSIDIARY, A FINE OF EUR 7 MILLION. HOWEVER IN ITS 23 FEBRUARY, 2012 ORDER, THE FRENCH COURT OF APPEAL, TO WHICH THE MATTER WAS REFERRED BY ALL THE BANKS INVOLVED EXCEPT BANQUE DU FRANCE, HELD THAT THERE WAS NO COMPETITION LAW INFRINGEMENT ALLOWING THE BANKS TO RECOUP THE FINES PAID. ON 14 APRIL 2015, THE SUPREME COURT QUASHED AND ANNULLED THE COURT OF APPEAL DECISION ON THE GROUNDS THAT THE LATTER DID NOT EXAMINE THE ARGUMENTS OF TWO THIRD PARTIES WHO VOLUNTARILY INTERVENED IN THE PROCEEDINGS. THE CASE WAS HEARD AGAIN ON 3 AND 4 NOVEMBER 2016 BY THE PARIS COURT OF APPEAL BEFORE WHICH THE CASE WAS REMANDED. ON 21 DECEMBER 2017, THE COURT OF APPEAL CONFIRMED THE FINES IMPOSED ON SOCIÉTÉ GÉNÉRALE AND CREDIT DU NORD BY THE FRENCH COMPETITION AUTHORITY. ON 22 JANUARY 2018, SOCIÉTÉ GÉNÉRALE AND CREDIT DU NORD FILED AN APPEAL BEFORE THE SUPREME COURT AGAINST THIS DECISION. ON 29 JANUARY THE SUPREME COURT PARTIALLY QUASHED THE ORDER THE PARIS COURT OF APPEAL DECISIONS OF 21 DECEMBER 2017 AND ORDERED THE REMAND OF THE CASE TO THIS SAME COURT OF APPEAL BUT DIFFERENTLY COMPOSED. ON 13 MARCH 2020, SOCIÉTÉ GÉNÉRALE AND CREDIT DU NORD FILED A NEW APPEAL BEFORE THE PARIS COURT OF APPEAL AGAINST THE DECISION OF THE FRENCH COMPETITION AUTHORITY. ON JUNE 28, 2023, THE FRENCH SUPREME COURT UPHELD THE PARIS COURT OF APPEALS JUDGMENT WHICH REVERSED THE 2010 DECISION BY THE FCA FINING SG, FINDING THAT THE FCA FAILED TO PROVE THE FIRMS HAD ENGAGED IN ANTI-COMPETITIVE PRICING.
Other filed details
Description of allegations — filed text
FOLLOWING AN INVESTIGATION, THE FRENCH COMPETITION AUTHORITY (AUTORITE DE LA CONCURRENCE) ISSUED A DECISION FINDING THAT ELEVEN (11) MAJOR FRENCH RETAIL BANKS, INCLUDING SOCIÉTÉ GÉNÉRALE AND ITS SUBSIDIARY, CREDIT DU NORD, HAD ENGAGED IN ANTICOMPETITIVE ACTIVITY IN CONNECTION WITH FEES ASSOCIATED WITH ELECTRONIC CHECK PROCESSING SERVICES AND CERTAIN OTHER FEES FOR RELATED SERVICES IN FRANCE. THE AUTHORITY FOUND THAT A FEE OF 0.043 EUROS PER CHECK WAS UNJUSTIFIED AND AN INFRINGEMENT OF COMPETITION RULE IN FRANCE AND THAT CERTAIN OTHER FEES WERE NOT PROPORTIONATE TO COSTS INCURRED BY THE BANKS. THE PRIMARY PROCESSING FEES WERE CHARGED BETWEEN JANUARY 2022 AND JULY 2007. THE GROUP OF 11 BANKS WAS FINED A TOTAL OF 348.92 MILLION EUROS. SOCIÉTÉ GÉNÉRALE WAS FINED 53.47 MILLION EUROS AND CREDIT DU NORD WAS FINED 6.98 MILLION EUROS.
Sanction detail — filed text
ON JUNE 28, 2023, THE FRENCH SUPREME COURT UPHELD THE PARIS COURT OF APPEALS JUDGMENT WHICH REVERSED THE 2010 DECISION BY THE FCA FINING SG, FINDING THAT THE FCA FAILED TO PROVE THE FIRMS HAD ENGAGED IN ANTI-COMPETITIVE PRICING. THE MATTER WAS DISMISSED.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) THE FRENCH COMPETITION AUTHORITY 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 09/20/2010 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Annuity(ies) - Variable Other Product Types: yp 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FOLLOWING AN INVESTIGATION, THE FRENCH COMPETITION AUTHORITY (AUTORITE DE LA CONCURRENCE) ISSUED A DECISION FINDING THAT ELEVEN (11) MAJOR FRENCH RETAIL BANKS, INCLUDING SOCIÉTÉ GÉNÉRALE AND ITS SUBSIDIARY, CREDIT DU NORD, HAD ENGAGED IN ANTICOMPETITIVE ACTIVITY IN CONNECTION WITH FEES ASSOCIATED WITH ELECTRONIC CHECK PROCESSING SERVICES AND CERTAIN OTHER FEES FOR RELATED SERVICES IN FRANCE. THE AUTHORITY FOUND THAT A FEE OF 0.043 EUROS PER CHECK WAS UNJUSTIFIED AND AN INFRINGEMENT OF COMPETITION RULE IN FRANCE AND THAT CERTAIN OTHER FEES WERE NOT PROPORTIONATE TO COSTS INCURRED BY THE BANKS. THE PRIMARY PROCESSING FEES WERE CHARGED BETWEEN JANUARY 2022 AND JULY 2007. THE GROUP OF 11 BANKS WAS FINED A TOTAL OF 348.92 MILLION EUROS. SOCIÉTÉ GÉNÉRALE WAS FINED 53.47 MILLION EUROS AND CREDIT DU NORD WAS FINED 6.98 MILLION EUROS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Dismissed 11. Resolution Date (MM/DD/YYYY): 06/28/2023 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 58,870,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON JUNE 28, 2023, THE FRENCH SUPREME COURT UPHELD THE PARIS COURT OF APPEALS JUDGMENT WHICH REVERSED THE 2010 DECISION BY THE FCA FINING SG, FINDING THAT THE FCA FAILED TO PROVE THE FIRMS HAD ENGAGED IN ANTI-COMPETITIVE PRICING. THE MATTER WAS DISMISSED. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). IN THE EARLY 2000S, THE FRENCH BANKING INDUSTRY DECIDED TO TRANSITION TO A NEW DIGITAL SYSTEM IN ORDER TO STREAMLINE CHEQUE CLEARING. TO SUPPORT THIS REFORM, WHICH HAS CONTRIBUTED TO THE IMPROVEMENT OF CHEQUE PAYMENTS SECURITY AND TO THE FIGHT AGAINST FRAUD, THE BANKS ESTABLISHED SEVERAL INTERBANK FEES, INCLUDING THE CEIC WHICH WAS ABOLISHED IN 2007. THESE FEES WERE IMPLEMENTED UNDER THE AEGIS OF THE BANKING SECTOR SUPERVISORY AUTHORITIES, AND TO THE KNOWLEDGE OF THE PUBLIC AUTHORITIES. ON 20, SEPTEMBER 2010, AFTER SEVERAL YEARS OF INVESTIGATION, THE FRENCH COMPETITION AUTHORITY RULED THAT THE JOINT IMPLEMENTATION AND THE SETTING OF THE AMOUNT OF THE CEIC AND OF TWO ADDITIONAL FEES FOR RELATED SERVICES WERE IN BREACH OF COMPETITION LAW. THE AUTHORITY FINED ALL PARTICIPANTS TO THE AGREEMENT (INCLUDING THE BANQUE DU FRANCE) A TOTAL OF APPROXIMATELY EUR 53.5 MILLION. SOCIÉTÉ GÉNÉRALE WAS ORDERED TO PAY A FINE OF EUR 385 MILLION AND CREDIT DU NORD, ITS SUBSIDIARY, A FINE OF EUR 7 MILLION. HOWEVER IN ITS 23 FEBRUARY, 2012 ORDER, THE FRENCH COURT OF APPEAL, TO WHICH THE MATTER WAS REFERRED BY ALL THE BANKS INVOLVED EXCEPT BANQUE DU FRANCE, HELD THAT THERE WAS NO COMPETITION LAW INFRINGEMENT ALLOWING THE BANKS TO RECOUP THE FINES PAID. ON 14 APRIL 2015, THE SUPREME COURT QUASHED AND ANNULLED THE COURT OF APPEAL DECISION ON THE GROUNDS THAT THE LATTER DID NOT EXAMINE THE ARGUMENTS OF TWO THIRD PARTIES WHO VOLUNTARILY INTERVENED IN THE PROCEEDINGS. THE CASE WAS HEARD AGAIN ON 3 AND 4 NOVEMBER 2016 BY THE PARIS COURT OF APPEAL BEFORE WHICH THE CASE WAS REMANDED. ON 21 DECEMBER 2017, THE COURT OF APPEAL CONFIRMED THE FINES IMPOSED ON SOCIÉTÉ GÉNÉRALE AND CREDIT DU NORD BY THE FRENCH COMPETITION AUTHORITY. ON 22 JANUARY 2018, SOCIÉTÉ GÉNÉRALE AND CREDIT DU NORD FILED AN APPEAL BEFORE THE SUPREME COURT AGAINST THIS DECISION. ON 29 JANUARY THE SUPREME COURT PARTIALLY QUASHED THE ORDER THE PARIS COURT OF APPEAL DECISIONS OF 21 DECEMBER 2017 AND ORDERED THE REMAND OF THE CASE TO THIS SAME COURT OF APPEAL BUT DIFFERENTLY COMPOSED. ON 13 MARCH 2020, SOCIÉTÉ GÉNÉRALE AND CREDIT DU NORD FILED A NEW APPEAL BEFORE THE PARIS COURT OF APPEAL AGAINST THE DECISION OF THE FRENCH COMPETITION AUTHORITY. ON JUNE 28, 2023, THE FRENCH SUPREME COURT UPHELD THE PARIS COURT OF APPEALS JUDGMENT WHICH REVERSED THE 2010 DECISION BY THE FCA FINING SG, FINDING THAT THE FCA FAILED TO PROVE THE FIRMS HAD ENGAGED IN ANTI-COMPETITIVE PRICING.
regulatory · block 31SOCIÉTÉ GÉNÉRALE S.A.PDF pages 86–88
- Advisory affiliate name — filed text
- SOCIÉTÉ GÉNÉRALE S.A.
- Regulator name — filed text
- ICE CLEAR CREDIT LLC
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Other filed details
Description of allegations — filed text
ICE CLEAR CREDIT LCC (ICE CLEAR) ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR 18 MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN MARCH 2018. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON APRIL 24, 2018, AFTER SG DETERMINED NOT TO SEEK WAIVER.
Sanction detail — filed text
ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: SOCIÉTÉ GÉNÉRALE S.A. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) ICE CLEAR CREDIT LLC 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 04/09/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018-404B-009 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: CREDIT DEFAULT SWAP 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ICE CLEAR CREDIT LCC (ICE CLEAR) ISSUED A $10,000 ASSESSMENT TO SOCIÉTÉ GÉNÉRALE (SG) FOR 18 MISSED END OF DAY CREDIT DEFAULT SWAP PRICING SUBMISSIONS IN MARCH 2018. THE ASSESSMENT WAS CALCULATED ACCORDING TO ICE CLEAR'S SCHEDULE OF ASSESSMENTS UNDER ICE CLEAR RULE 702(E), PURSUANT TO WHICH ASSESSMENT AMOUNTS ARE ISSUED ACCORDING TO A "PER MISSED PRICE" SCHEDULE, SUBJECT TO CERTAIN DAILY MAXIMUMS. THE ASSESSMENT BECAME FINAL ON APRIL 24, 2018, AFTER SG DETERMINED NOT TO SEEK WAIVER. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Other 11. Resolution Date (MM/DD/YYYY): 04/24/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 10,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.
regulatory · block 32SOCIETE GENERALE SAPDF pages 88–90
- Advisory affiliate name — filed text
- SOCIETE GENERALE SA
- Regulator name — filed text
- FINANCIAL SERVICES COMMISSION (KOREA)
- Monetary/Fine Amount — filed text
- $ 520,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE FSC ISSUED A FINAL NOTICE OF PENALTY AGAINST SOCIETE GENERALE, FINDING THAT BETWEEN OCTOBER 12, 2021 AND DECEMBER 23, 2022, SOCIETE GENERALE VIOLATED SHORT SELL REGULATIONS UNDER ARTIC E 180, PARAGRAPH 1, ITEM 1 OF THE FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT, ARTICLE 429-3, PARAGRAPH 1 OF THE SAME ACT, ARTIC E 379, PARAGRAPH 2 OF THE ENFORCEMENT DECREE OF THE SAME ACT, ARTIC E 25, PARAGRAPH 3, AND APPENDIX 2 OF THE CAPITAL MARKET INVESTIGATION BUSINESS REGULATIONS, BY SUBMITTING A SHORT SELL ORDER FOR 27,784 SHARES IN THREE STOCKS WITHOUT OWNING OR COVERING THE SHARES.
Other filed details
Description of allegations — filed text
THE FINANCIAL SERVICES COMMISSION ("FSC") ISSUED A FINAL NOTICE OF PENALTY AGAINST SOCIETE GENERALE, FINDING THAT BETWEEN OCTOBER 12, 2021 AND DECEMBER 23, 2022, SOCIETE GENERALE VIOLATED SHORT SELL REGULATIONS UNDER ARTICLE 180, PARAGRAPH 1, ITEM 1 OF THE FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT, ARTICLE 429-3, PARAGRAPH 1 OF THE SAME ACT, ARTICLE 379, PARAGRAPH 2 OF THE ENFORCEMENT DECREE OF THE SAME ACT, ARTICLE 25, PARAGRAPH 3, AND APPENDIX 2 OF THE CAPITAL MARKET INVESTIGATION BUSINESS REGULATIONS, BY SUBMITTING A SHORT SELL ORDER FOR 27,784 SHARES IN THREE STOCKS WITHOUT OWNING OR COVERING THE SHARES.
Sanction detail — filed text
N/A
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SOCIETE GENERALE SA
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINANCIAL SERVICES COMMISSION (KOREA)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
11/20/2024
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2025-69
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FINANCIAL SERVICES COMMISSION ("FSC") ISSUED A FINAL NOTICE OF PENALTY AGAINST SOCIETE GENERALE, FINDING THAT BETWEEN OCTOBER
12, 2021 AND DECEMBER 23, 2022, SOCIETE GENERALE VIOLATED SHORT SELL REGULATIONS UNDER ARTICLE 180, PARAGRAPH 1, ITEM 1 OF THE
FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT, ARTICLE 429-3, PARAGRAPH 1 OF THE SAME ACT, ARTICLE 379, PARAGRAPH 2 OF THE
ENFORCEMENT DECREE OF THE SAME ACT, ARTICLE 25, PARAGRAPH 3, AND APPENDIX 2 OF THE CAPITAL MARKET INVESTIGATION BUSINESS
REGULATIONS, BY SUBMITTING A SHORT SELL ORDER FOR 27,784 SHARES IN THREE STOCKS WITHOUT OWNING OR COVERING THE SHARES.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
03/12/2025
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 520,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
N/A
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE FSC ISSUED A FINAL NOTICE OF PENALTY AGAINST SOCIETE GENERALE, FINDING THAT BETWEEN OCTOBER 12, 2021 AND DECEMBER 23, 2022,
SOCIETE GENERALE VIOLATED SHORT SELL REGULATIONS UNDER ARTIC E 180, PARAGRAPH 1, ITEM 1 OF THE FINANCIAL INVESTMENT SERVICES AND
CAPITAL MARKETS ACT, ARTICLE 429-3, PARAGRAPH 1 OF THE SAME ACT, ARTIC E 379, PARAGRAPH 2 OF THE ENFORCEMENT DECREE OF THE SAME
ACT, ARTIC E 25, PARAGRAPH 3, AND APPENDIX 2 OF THE CAPITAL MARKET INVESTIGATION BUSINESS REGULATIONS, BY SUBMITTING A SHORT SELL
ORDER FOR 27,784 SHARES IN THREE STOCKS WITHOUT OWNING OR COVERING THE SHARES.* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.