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The Strip Club – Is Membership Now Closed?

With today’s announcements from the US Attorney for the Southern District of New York, OFAC, Federal Reserve, New York State Department of Financial Services, and the Manhattan DA’s Office, the almost-ten year “Strip Club” investigations and prosecutions may have come to a close. Today was Société Générale’s turn, closing a six year investigation into ten years of sanction violations with penalties totaling more than $1.34 billion paid to five county, state, and federal agencies. Notably, the Manhattan DA press release mentioned a “concealment practice” that ended in early 2007, and, because of SocGen’s alleged “untimely disclosure, the statute of limitations for violations relating to the concealment practice and to much of the conduct involving the Cuban credit facilities had already run by the time the investigating agencies learned of them.” The press release contains a list of, and links to, the ten banks that paid penalties for “stripping out” information about sanctioned entities in order to avoid US sanctions controls. Perhaps we’ve seen the last member added to the Manhattan DA’s “Strip Club” …  https://www.manhattanda.org/d-a-vance-announces-162-8-million-payment-from-societe-generale-to-new-york-city-and-state/ 

The most complete filing is from the Manhattan US Attorney’s office: see https://www.justice.gov/usao-sdny/press-release/file/1112461/download