The fight against money laundering: a reinforced system of prevention

The central team combating money laundering and the financing of terrorism is regularly strengthened, and its work is communicated to the retail banking in France and foreign Group entities by a network of more than 100 officers. These officers are responsible for monitoring the local laws and regulations in the country in which they operate, and to this end actively cooperate with the local authorities. They also ensure that the Group's procedures, defined on the basis of French legislation and the recommendations of the FATF or the Wolfsberg Group (*), are respected.

Specific training is provided on a regular basis to employees concerned, both in France and abroad, and dedicated computer applications have been developed to help detect any suspicious transactions.

(*) In October 2000, 11 banks, including one French bank, Société Générale, made public a code of good conduct relating to the fight against money laundering. Those banks, now 12 global banks, are known as the Wolfsberg Group. These principles were revised in June 2002, and to them were added recommendations concerning the fight against the financing of terrorism. The observation of these principles aims to manage these risks more effectively.

The fight against corruption

In 2004, Société Générale supported the addition of the 10th principle of the Global Compact, dedicated to the fight against corruption.
Société Générale rules concerning the fight against corruption are very strict, and are in compliance with the provisions of French legislation, in particular.
The obligatory provisions and inspections are distributed through updated directives that apply to the entire Group:
· as of 2001, the Group adopted a directive addressed to all staff, incorporating French provisions concerning the prevention of corruption of public representatives in Europe and abroad.
· in 2004, the directive on “the prevention of money laundering in the Group” was reviewed: the document now includes special control measures covering business relations with persons who are deemed to be politically exposed by virtue of their current or previous positions, and with companies associated with these persons.

Financing of terrorism: heightened vigilance

Following the events of September 11th 2001, the fight against the financing of terrorism took on a new dimension.
At Société Générale, specific directives have been issued to alert the various entities and their staff to their obligations with respect to due diligence and customer identification, cross-checking of customer files and transfer transactions, using dedicated computer applications, to detect the presence of natural persons and legal entities who are thought to be linked to terrorist activities and who appear on the lists issued by the public authorities, freezing of financial assets and, in some cases, declaration of suspicions to the competent authorities. Furthermore, the prevention of terrorism is now included in a number of training modules, in order to raise awareness among staff concerned.