Haussmann 1864 Capital Management Llc

Event Detail: 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. Status: Final Disposition: 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. Summary: 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.

Event Detail: 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. Status: Final Disposition: 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. Summary: 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").

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $1,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $1,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $71,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSION. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $71,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSION.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $129,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $129,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $110,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $110,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000 WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: FOR VARIOUS TRADE DATES FROM MARCH 2019 TO JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION WERE REPORTED FOR REPORTING # 0DG02 IN VIOLATION. Status: Final Sanction Detail: SUMMARY FINE FOR VARIOUS TRADE DATES FROM MARCH 2019 TO JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION. Summary: SUMMARY FINE FOR VARIOUS TRADE DATES FROM MARCH 2019 TO JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION.

Allegations: 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. Status: Final Sanction Detail: IFUS SETTLED THE MATTER. Summary: 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.

Allegations: 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. Status: Final Sanction Detail: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $10,000, WHICH WAS CALCULATED ACCORDING TO ITS RULE 702(E) SCHEDULE OF ASSESSMENTS FOR MISSED SUBMISSIONS.

Allegations: 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). Status: Final Sanction Detail: 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. Summary: 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.

Allegations: THE FINANCIAL MARKET AUTHORITY (AMF) FINED SOCIÉTÉ GÉNÉRALE 500,000 EUROS FOR (1) BREACHING ARTICLE 332-6 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. Status: Final Sanction Detail: THE AMF FINED SOCIÉTÉ GÉNÉRALE 500,000 EUROS EQUALING $636,610 U.S. AS OF 11/7/2008. Summary: THE AMF FINED SOCIÉTÉ GÉNÉRALE 500,000 EUROS EQUALING $636,610 U.S. AS OF 11/7/2008.

Allegations: 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). Status: Final Sanction Detail: 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). Summary: 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).

Allegations: 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. Status: Final Sanction Detail: 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. Summary: 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.

Allegations: SOCIÉTÉ GÉNÉRALE (SG) WAS THE SUBJECT OF AN ON-SITE 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. Status: Final Sanction Detail: 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. Summary: 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.

Allegations: 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. Status: Final Sanction Detail: SOCIÉTÉ GÉNÉRALE WAS FINED 1.575 MILLION BRITISH POUNDS. Summary: SOCIÉTÉ GÉNÉRALE WAS FINED 1.575 MILLION BRITISH POUNDS.

Allegations: 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). Status: Final Sanction Detail: 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. Summary: 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.

Allegations: 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. Status: Final Sanction Detail: 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. Summary: 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.

Allegations: 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. Status: Final Sanction Detail: 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. Summary: 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.

Allegations: 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. Status: Final Sanction Detail: 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). Summary: 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).

Allegations: 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. Status: Final Sanction Detail: 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. Summary: 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.

Allegations: 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). Status: Final Sanction Detail: 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). Summary: 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).

Allegations: 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). Status: Final Sanction Detail: 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). Summary: 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).

Allegations: 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. Status: Final Sanction Detail: 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. Summary: 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.

Allegations: 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. Status: Final Sanction Detail: 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. Summary: 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.

Allegations: THE COMMISSION FOUND THAT SOCIÉTÉ GÉNÉRALE (SG) INADVERTENTLY FAILED TO REPORT TO SWAP DATA DEPOSITORY CERTAIN NON-DELIVERABLE 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). Status: Final Sanction Detail: SG AGREED TO A FINE OF $450,000 AND WAS ORDERED TO CEASE AND DESIST FROM FUTURE VIOLATIONS. Summary: SG AGREED TO A FINE OF $450,000 AND WAS ORDERED TO CEASE AND DESIST FROM FUTURE VIOLATIONS.

Allegations: 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. Status: Final Sanction Detail: 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. Summary: 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.