On June 4, 2018, DOJ officials announced a non-prosecution agreement with investment management firm Legg Mason, Inc., which agreed to pay $64 million in penalties and disgorgement to resolve FCPA liability related to bribery of officials of Libyan state-owned financial institutions.  According to the agreed-upon statement of facts in the resolution, Legg Mason subsidiary Permal Group Ltd. (“Permal”) partnered with Paris-based multinational bank Société Générale S.A. (“SocGen”) to solicit investment management business from Libyan state-owned institutions.  SocGen reportedly paid $90 million in commissions to a Libyan intermediary in connection with 14 investments made by state-owned institutions between 2004 and 2010; portions of these commissions were reportedly directed to Libyan government officials.  Permal managed seven of the 14 investments solicited by SocGen, earning $31.6 million in profits.  In announcing the resolution with Legg Mason, DOJ officials noted that although the company did not voluntarily or timely disclose the conduct at issue, it subsequently cooperated and fully remediated the issues.  Officials further noted that the misconduct involved only mid-to-lower-level employees of LeggMason subsidiary Permal, noting by contrast that SocGen maintained a relationship with the Libyan intermediary who originated the bribery scheme.  SocGen reached a separate resolution with U.S. and French authorities in connection with the bribery scheme and other misconduct.

DOJ Press Release