Despite Rhetoric, DOJ “Piled On” Société Générale

In a new blog post on FCPA Professor, Mike Koehler argues that the Department of Justice's enforcement action against Société Générale for its bribery of Libyan officials was an example of the "piling on" that DOJ swore to avoid in recent guidance.  While DOJ's enforcement action provided an offset for $293 million paid to French law enforcement, Koehler notes that Société Générale has already paid approximately $1.1 billion to the Libyan Investment Authority to resolve a related civil dispute.