EvilCorporations.com · Corporate Accountability Project
Federal Criminal Charges
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Société Générale Bribed Gaddafi Officials and Rigged Global Interest Rates for Half a Billion in Profit
The French banking giant paid nearly $91 million in bribes to Libyan government insiders and deliberately falsified the interest rates that set borrowing costs for millions of ordinary people worldwide.
🔴 CRITICAL SEVERITY
TL;DR
Between 2005 and 2011, Société Générale S.A. paid approximately $90.74 million in bribes, routed through a shadowy Libyan intermediary and a Panamanian shell company, to corrupt officials inside Gaddafi’s Libyan government. These payments bought the bank $3.66 billion in investment deals from Libyan state agencies and generated $523 million in profits for Société Générale. At the same time, the bank submitted false and artificially low USD LIBOR rates to global financial authorities to disguise its actual borrowing costs, manipulating a benchmark rate used to set interest rates on credit cards, home mortgages, and derivatives contracts affecting ordinary people around the world. This was not a rogue trader or a single bad actor. This was a coordinated conspiracy by Société Générale employees who knew about the bribery and chose to continue it anyway.
This is what corporate power looks like when it operates without consequence. Demand accountability.
Key Numbers
$3.66B
Investment deals won via bribery from Libyan state agencies
$523M
Profits earned by Société Générale from the bribed deals
$90.74M
Total bribe payments to Libyan intermediary, 2005–2009
$19.8M
Single wire transfer through Société Générale’s New York branch to the bribe intermediary (April 2008)
13
Structured notes sold to Libyan state agencies as part of the bribery scheme
6 yrs
Duration of bribery conspiracy (2005–2011)
Allegations Breakdown
Core Allegations
What Société Générale Did · 6 Points
| 01 | Société Générale employees conspired to pay bribes to Libyan government officials through a dual Libyan-Italian intermediary based in Dubai and London, knowing since at least 2006 that the intermediary was funneling improper payments to Gaddafi-era officials. | high |
| 02 | Société Générale concealed bribe payments by disguising them as fees for purported “introduction services” paid to the Libyan Intermediary’s Panamanian company, a structure designed to obscure the corrupt nature of the payments. | high |
| 03 | The bribes secured 13 structured notes and one restructuring deal totaling $3.66 billion in investments from four Libyan state agencies: the Central Bank of Libya, the Libyan Arab Foreign Bank, the Economic and Social Development Fund, and the Libyan Investment Authority. | high |
| 04 | Société Générale paid commissions of between 1.5% and 3% of each investment’s nominal amount to the Libyan Intermediary’s Panamanian Company, totaling approximately $90.74 million from 2005 to 2009. | high |
| 05 | Société Générale submitted false and artificially low USD LIBOR rates to the British Bankers’ Association via Thomson Reuters from May 2010 through October 2011, misrepresenting its actual borrowing costs to protect its public reputation. | high |
| 06 | On at least two documented occasions in June 2010, Société Générale submitted a three-month USD LIBOR contribution of 0.5525 on the same days it borrowed money in the market at rates ranging from 0.58 to 0.65, a direct contradiction proving its submissions were false. | high |
Profit Over People
Revenue Prioritized Over Ethics · 4 Points
| 01 | Société Générale earned approximately $523 million in profits directly from the 13 structured note deals obtained through bribery, meaning the bank’s entire profit on this portfolio was tainted by corruption. | high |
| 02 | When employees knew that continuing to use the Libyan Intermediary meant funding corruption, Société Générale chose to continue the relationship anyway, treating bribery as an acceptable cost of doing business. | high |
| 03 | The LIBOR manipulation was driven by Société Générale’s desire to protect its reputation by appearing financially stronger than it was, placing the bank’s image above market integrity and the interests of counterparties who relied on accurate rate data. | high |
| 04 | Société Générale competed aggressively against at least eight other U.S.-based financial institutions for the Libyan state agency investments, and chose bribery as its competitive weapon rather than offering superior financial products or pricing. | medium |
LIBOR Manipulation and Global Market Harm
Falsifying the Rate That Priced Everything · 5 Points
| 01 | USD LIBOR, the rate Société Générale manipulated, was used to price Eurodollar futures contracts traded on the Chicago Mercantile Exchange, interest rate swaps, fixed-income futures, options, forward rate agreements, and credit card and home mortgage interest rates. | high |
| 02 | Société Générale was a member of the USD LIBOR Contributor Panel from February 2009, meaning it held a position of institutional trust responsible for providing honest borrowing rate estimates that the entire global financial system relied upon. | high |
| 03 | The British Bankers’ Association rules explicitly required each Contributor Panel bank to provide honest and unbiased estimates of its borrowing costs. Société Générale violated this obligation knowingly and willfully. | high |
| 04 | Thomson Reuters transmitted all Contributor Panel banks’ individual LIBOR submissions to three data centers worldwide for public publication, including one in Hauppauge, New York, meaning Société Générale’s false submissions entered the U.S. financial system directly. | medium |
| 05 | On June 14 and June 16, 2010, Société Générale submitted LIBOR contributions of 0.5525% while simultaneously borrowing in the actual market at rates between 0.58% and 0.65%, providing documented proof that its submissions were false and misleading. | high |
Corporate Accountability Failures
Structure of the Cover-Up · 4 Points
| 01 | Société Générale employees concealed bribe payments by categorizing them as commissions for “introduction services,” creating a paper trail that disguised the corrupt purpose of the payments as routine business expenses. | high |
| 02 | The Libyan Intermediary used a Panamanian shell company to receive commission payments from Société Générale, and then transferred portions of those funds directly to relatives of Libyan officials, building in an additional layer of financial opacity. | high |
| 03 | The Libyan Intermediary served as a legal “agent” of Société Générale under U.S. law, meaning the bank bears direct legal responsibility for the bribery conducted on its behalf, regardless of how many intermediary layers were used to obscure the payments. | high |
| 04 | No individual Société Générale executives are named as defendants in this criminal information. The company alone faces prosecution, a pattern that allows the individuals who made these decisions to escape personal criminal accountability. | medium |
Profiting from Complexity
Shell Companies and Financial Opacity · 3 Points
| 01 | SGA Société Générale Acceptance, N.V., a subsidiary organized under the laws of Curacao, was used to issue structured notes to Libyan state agencies, placing an additional corporate layer between the French parent bank and the corrupt transactions. | medium |
| 02 | Structured notes sold to the Libyan state agencies were described in the charges as “complicated securities that typically combine a debt obligation and a derivative component,” a level of complexity that obscured the true financial relationship and made independent assessment by the Libyan agencies difficult. | medium |
| 03 | Société Générale used a Panamanian company controlled by a Dubai-based intermediary to receive and funnel bribe payments, creating a cross-jurisdictional structure specifically designed to place the corruption beyond the easy reach of any single country’s enforcement authorities. | high |
Timeline of Events
~2005
Société Générale begins paying commissions to the Libyan Intermediary’s Panamanian Company to secure investments from Libyan state agencies. The bribery conspiracy begins.
By 2006
Several Société Générale employees know the Libyan Intermediary is paying bribes and providing improper benefits to Libyan government officials. The bank continues the relationship anyway.
2005–2011
Société Générale and the Investment Management Firm sell 13 structured notes (and one restructuring) worth $3.66 billion to Libyan state agencies, generating $523 million in profits for Société Générale.
April 28, 2008
Société Générale sends a wire transfer of approximately $19.8 million through its New York branch to the Panamanian Company’s account in Zurich, Switzerland, one of the documented overt acts of the conspiracy.
May 9, 2008
The Libyan Intermediary wires $7.5 million from the $19.8 million received from Société Générale directly to a relative of a Libyan official. A Société Générale employee and the Intermediary also travel to New York to meet with a Libyan official and provide entertainment.
2005–2009
Total bribe payments to the Libyan Intermediary reach approximately $90.74 million, paid as purported “introduction” commissions on the investments made by Libyan state agencies.
Feb 2009
Société Générale becomes a member of the USD LIBOR Contributor Panel, gaining the institutional responsibility to submit honest borrowing rate estimates used to set global benchmark rates.
May 2010–Oct 2011
Société Générale submits false and artificially low USD LIBOR rates to the British Bankers’ Association, misrepresenting its actual borrowing costs to protect its public financial reputation.
June 14–16, 2010
Société Générale submits a LIBOR contribution of 0.5525% on both days while borrowing in the actual market at rates between 0.58% and 0.65%, creating documented proof that its submissions were deliberately false.
June 11, 2018
The United States files a federal criminal information against Société Générale in the Eastern District of New York, charging the company with two counts of conspiracy.
Direct Quotes from the Federal Charges
QUOTE 1
Employees Knew and Chose to Continue
Core Allegations
“[S]everal SOCIÉTÉ GÉNÉRALE employees, together with their co-conspirators, knew that the Libyan Intermediary was paying bribes and providing other improper financial benefits to Libyan government officials in order to secure financial investments for SOCIÉTÉ GÉNÉRALE, and agreed to continue to use the Libyan Intermediary despite that knowledge.”
💡 This is not a case of a rogue actor. Senior Société Générale employees had full knowledge that corruption was funding their deals and chose to proceed anyway. That is a corporate decision, not an individual one.
QUOTE 2
Bribes Concealed as “Introduction Services”
Corporate Accountability Failures
“The SOCIÉTÉ GÉNÉRALE employees also concealed the bribes through payments to the Libyan Intermediary for purported ‘introduction’ services.”
💡 Creating false paper trails is not a technicality. It is a deliberate act of fraud designed to prevent regulators, auditors, and the public from ever discovering the corruption.
QUOTE 3
Scale of Bribed Investment Deals
Profit Over People
“[S]old the Libyan State Agencies 13 structured notes (and one restructuring) worth a total of approximately $3.66 billion. SOCIÉTÉ GÉNÉRALE earned profits of approximately $523 million in connection with these deals.”
💡 $523 million in profits, every dollar of it generated through a bribery conspiracy. The scale of the financial gain makes this not a lapse in judgment but a deliberate and sustained business strategy.
QUOTE 4
Total Bribe Payments Quantified
Core Allegations
“[S]OCIÉTÉ GÉNÉRALE paid the Libyan Intermediary approximately $90.74 million from approximately 2005 to 2009 for supposed ‘introductory’ services.”
💡 Nearly $91 million in bribes paid over four years. This was not a one-time lapse. It was a sustained, funded, and institutionally approved corruption operation.
QUOTE 5
LIBOR Manipulation Motive Stated
LIBOR Manipulation and Global Market Harm
“The purpose of the scheme was to avoid anticipated reputational harm to SOCIÉTÉ GÉNÉRALE had it submitted honest estimates of its borrowing rates.”
💡 The bank chose to lie to the entire global financial system rather than admit it had higher borrowing costs. Millions of consumers whose mortgages and credit cards were priced off LIBOR paid for that lie.
QUOTE 6
Proof of False LIBOR Submissions
LIBOR Manipulation and Global Market Harm
“[O]n or about June 14, 2010, SOCIÉTÉ GÉNÉRALE submitted a USD LIBOR contribution in the three-month tenor of 0.5525. On that same day, SOCIÉTÉ GÉNÉRALE borrowed money in the market at interest rates ranging from 0.58 to 0.63.”
💡 The document includes two separate days of documented proof that Société Générale’s stated rate and actual rate were different. This is not an estimation error. This is deliberate falsification.
QUOTE 7
LIBOR’s Reach Into Ordinary People’s Finances
LIBOR Manipulation and Global Market Harm
“LIBOR was also used in some instances to calculate credit card interest rates and home mortgage interest rates.”
💡 The victims of Société Générale’s LIBOR manipulation were not abstract market participants. They were homeowners and credit card holders whose costs were tied to a rate the bank was deliberately falsifying.
QUOTE 8
Wire Transfer Through New York Branch
Corporate Accountability Failures
“[O]n or about April 28, 2008, SOCIÉTÉ GÉNÉRALE sent a wire transfer of approximately $19.8 million through SOCIÉTÉ GÉNÉRALE’s New York branch to the Panamanian Company’s account at SOCIÉTÉ GÉNÉRALE in Zurich, Switzerland.”
💡 The bank used its own New York branch to route bribe money to its own Swiss office, then to a shell company. The corruption ran through Société Générale’s own infrastructure from start to finish.
Commentary
❓
Who were the victims of Société Générale’s bribery scheme?
▾
The most direct victims were the Libyan people. The Libyan state agencies that Société Générale bribed to win investment deals controlled sovereign wealth and public financial resources. Those funds belonged to Libyan citizens, not to corrupt officials. When a French bank pays bribes to corrupt insiders, it corrupts the institutions that are supposed to serve the public. The Libyan Investment Authority, the Central Bank of Libya, and the other state agencies were meant to steward national wealth. Société Générale helped undermine that stewardship for profit.
❓
How did Société Générale hide the bribery for years?
▾
The bank used multiple layers of financial opacity. Bribe payments were disguised as commissions for “introduction services,” a category of legitimate business expense that sounds routine. The money flowed from Société Générale’s New York branch to a Société Générale account in Zurich, then to a Panamanian company controlled by the intermediary, and from there to Libyan officials or their relatives. Each layer added distance between the bank and the corrupt end point. This kind of structured concealment does not happen by accident. It requires deliberate design.
❓
Who was actually harmed by the LIBOR manipulation?
▾
LIBOR underpinned an enormous portion of global financial activity. It set the rates on Eurodollar futures contracts, interest rate swaps, home mortgages, and credit card interest rates. When Société Générale submitted false low rates, it distorted the benchmark that every one of those financial products depended on. Homeowners whose mortgage rates were tied to LIBOR, consumers carrying credit card balances priced on LIBOR, and investors in LIBOR-based derivatives all transacted in a market that Société Générale was secretly manipulating. The harm was diffuse but real and enormous in aggregate.
❓
Is this lawsuit credible and serious?
▾
This is a federal criminal information filed by the United States Attorney for the Eastern District of New York, signed by the U.S. Attorney and the Acting Chief of the Fraud Section at the U.S. Department of Justice. It charges violations of the Foreign Corrupt Practices Act (18 U.S.C. 371, 3551) and conspiracy to transmit false commodities reports. It is not a civil suit or a regulatory complaint. This is a federal criminal case brought by the U.S. government after a documented investigation. The overt acts it describes include specific wire transfers, specific dollar amounts, and specific dates. This could not be more serious.
❓
Why is the structured note product itself relevant to the corruption?
▾
Structured notes are explicitly described in the charges as “complicated securities that typically combine a debt obligation and a derivative component.” Their complexity is directly relevant because it creates information asymmetry: the Libyan state agency officials who accepted the bribed investments may not have had the financial sophistication to independently evaluate whether the products were genuinely good investments or whether the terms favored Société Générale. Complexity serves corruption. When the buyer cannot fully assess the deal, the seller has more room to extract profit and the intermediary who brings the two parties together has more room to extract a bribe.
❓
How does this connect to broader patterns of corporate wrongdoing?
▾
Société Générale was not alone in these practices. The LIBOR manipulation scandal involved multiple major global banks, all submitting false rate estimates to protect their reputations and, in some cases, to profit on derivative positions. The Libya bribery scheme mirrors patterns seen across the extractive industries, financial services sector, and weapons trade: when Western corporations pursue revenues in politically unstable, resource-rich, or sanction-emerging markets, they frequently use intermediaries and shell companies to route corrupt payments. The FCPA was designed specifically to prevent this. The fact that Société Générale engaged in both schemes simultaneously shows how deeply embedded these practices can become in global financial institutions.
❓
Why were no individual executives charged in this filing?
▾
The criminal information names only Société Générale S.A. as the defendant, not any individual executives or employees. This is a recurring pattern in corporate fraud cases: the company pays a fine, pleads guilty, and the individuals who made the decisions face no personal consequences. The document does describe a “Libyan Intermediary” whose identity is known to the United States, which suggests the government has information about individuals but chose to focus the criminal information on the institution. The absence of individual accountability is itself a failure of the accountability system. Corporations do not make decisions. People do.
❓
What can I do to prevent this from happening again?
▾
You have real power here. First, contact your elected representatives and demand stronger FCPA enforcement with mandatory individual prosecutions, not just corporate fines that get passed to shareholders. Second, support investigative journalism and nonprofit accountability organizations that track corporate corruption, because this case only became public because of federal investigators. Third, if you work in finance, banking, or any industry with international operations, familiarize yourself with FCPA whistleblower protections: the SEC pays whistleblower awards of 10–30% of sanctions over $1 million. Fourth, divest from or pressure pension funds and institutional investors to divest from financial institutions with repeated corruption violations. Finally, share this story. Corporate misconduct thrives in obscurity. Sunlight is still the best disinfectant.
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