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Event Detail: TWO FELONY COUNTS OF CONSPIRACY TO COMMIT OFFENSES AGAINST THE UNITED STATES, IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 371 (FIRST COUNT, TO VIOLATE THE ANTI-BRIBERY PROVISIONS OF THE FOREIGN CORRUPT PRACTICES ACT OF 1977, AS AMENDED, TITLE 15, U.S. CODE, SECTIONS 78DD-2 AND 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. DEPT OF JUSTICE AND THE U.S. ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NY IN WHICH SG ACCEPTED RESPONSIBILITY FOR CONSPIRACY TO COMMIT OFFENSES AGAINST THE U.S., IN VIOLATION OF TITLE 18, USC, SEC. 371, AS DESCRIBED IN THE DPA'S STATEMENT OF FACTS. THE 1ST COUNT RELATED TO THE CONDUCT OF CERTAIN EMPLOYEES OF SG WHO, BY AT LEAST 2006, KNEW THAT AN INTERMEDIARY USED FOR CERTAIN TRANSACTIONS 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 DOLLAR 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"). 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 FOR THE LIBOR VIOLATIONS, IN THE AMOUNT OF $275,000,000. THE DOJ PAYMENTS WERE WIRED ON JUNE 15, 2018. Summary: CRIMINAL DIVISION OF THE UNITED STATES DEPARTMENT OF JUSTICE AND THE UNITED STATES ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NEW YORK (TOGETHER, THE "DOJ") IN WHICH SOCIÉTÉ GÉNÉRALE ACCEPTED RESPONSIBILITY FOR CONSPIRACY TO COMMIT OFFENSES AGAINST THE UNITED STATES, IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 371, AS DESCRIBED IN THE DPA'S STATEMENT OF FACTS THE FIRST COUNT RELATED TO THE CONDUCT OF CERTAIN EMPLOYEES OF SOCIÉTÉ GÉNÉRALE WHO, BY AT LEAST 2006, KNEW THAT AN INTERMEDIARY USED FOR CERTAIN TRANSACTIONS 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 SOCIÉTÉ GÉNÉRALE, AND AGREED TO CONTINUE TO USE THE INTERMEDIARY DESPITE THAT KNOWLEDGE (THE "FCPA VIOLATIONS"). THE SECOND COUNT RELATED TO THE CONDUCT OF CERTAIN EMPLOYEES OF SOCIÉTÉ GÉNÉRALE WHO (I) BETWEEN MAY 2010 AND AT LEAST OCTOBER 2011, PROMULGATED FALSE AND MISLEADING U.S. DOLLAR (USD) LIBOR SUBMISSIONS AND (II) IN 2006, PROMULGATED FALSE AND MISLEADING JAPAN YEN (JPY) LIBOR SUBMISSIONS, BOTH IN VIOLATION OF TITLE 7, UNITED STATES CODE, SECTION 13(A)(2) (TOGETHER, THE "LIBOR VIOLATIONS"). THE DOJ, UNDER THE TERMS OF THE DPA, AGREED TO DEFER PROSECUTION OF SOCIÉTÉ GÉNÉRALE IN CONNECTION WITH THE FCPA AND LIBOR VIOLATIONS. THE TERM OF THE DPA IS THREE (3) YEARS. SOCIÉTÉ GÉNÉRALE, UNDER THE DPA, AGREED, ON BEHALF OF ITSELF AND ITS SUBSIDIARIES, TO CERTAIN NOTICE, DISCLOSURE, AND COOPERATION REQUIREMENTS. FURTHER, SOCIÉTÉ GÉNÉRALE AGREED TO A MONETARY PENALTY OF $860,552,888, CONSISTING OF (I) A MONETARY PENALTY FOR THE FCPA VIOLATIONS IN THE AMOUNT OF $585,552,888, AGAINST WHICH SOCIÉTÉ GÉNÉRALE RECEIVED CREDIT FOR A $500,000 CRIMINAL MONETARY PENALTY AGREED TO BY SOCIÉTÉ GÉNÉRALE'S SUBSIDIARY, SGA SOCIÉTÉ GÉNÉRALE ACCEPTANCE, N.V. UNDER A PLEA AGREEMENT WITH THE DOJ AND A $292,776,444 PAYMENT MADE BY SOCIÉTÉ GÉNÉRALE AS PART OF A CRIMINAL RESOLUTION WITH THE PARQUET NATIONAL FINANCIER ("PNF") CONCERNING CONDUCT RELATED TO THE FCPA VIOLATIONS AND (II) A MONETARY PENALTY FOR THE LIBOR VIOLATIONS, IN THE AMOUNT OF $275,000,000. THE DOJ PAYMENTS WERE WIRED ON JUNE 15, 2018.

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, SOCIETE GENERALE, S.A. ("SG"), ENTERED INTO A DEFERRED PROSECUTION AGREEMENT ("DPA") WITH THE U.S. 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 ("USD") TRANSACTIONS USING THE U.S. FINANCIAL SYSTEM IN CONNECTION WITH CREDIT FACILITIES INVOLVING CUBA. THE CHARGED CONDUCT TOOK PLACE FROM AT LEAST 2004 UP THROUGH AND INCLUDING 2010 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. UNDER THE TERMS OF THE DPA, SG (I) AGREED TO PAY $717,200,000; (II) STIPULATED TO A STATEMENT OF FACTS DESCRIBING THE CONDUCT AT ISSUE; AND (III) 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 SETTLEMENT AGREEMENTS ENTERED INTO BY SG ON THE SAME DAY WITH OTHER FEDERAL AND STATE AUTHORITIES ("RELATED AGREEMENTS," AS DESCRIBED BELOW) AND OTHER EQUIVALENT ORDERS ISSUED BY SG'S U.S. FEDERAL OR STATE REGULATORS RELATING TO SG'S SANCTIONS OR BAN

Allegations: ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIETE GENERALE (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 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 SOCIETE GENERALE (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: FOR VARIOUS TRADE DATES FROM MARCH 2019 - JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION WERE REPORTED FOR REPORTING # 0DG02 IN VIOLATION. Status: Final Sanction Detail: SUMMARY FINE Summary: FOR VARIOUS TRADE DATES FROM MARCH 2019 - JULY 2021, INCORRECT POSITIONS AND INCORRECT OCR 102A INFORMATION.

Allegations: ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $110,000 ASSESSMENT TO SOCIETE GENERALE (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 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 $129,000 ASSESSMENT TO SOCIETE GENERALE 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, SUBJECT TO CERTAIN DAILY MAXIMUMS. 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 SOCIETE GENERALE (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 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: THE ACPR, IN CHARGE OF OVERSEEING THE (FRENCH) BANKING AND INSURANCE SECTORS, CONDUCTED AN ONSITE EXAMINATION FROM SEPTEMBER 8 TO DECEMBER 1, 2015 REGARDING SOCIÉTÉ GÉNÉRALE'S (SG)'S PROCEDURES FOR SUSPICIOUS ACTIVITY REPORTING (SAR). ON JUNE 5, 2016, THE ACPR INITIATED A DISCIPLINARY PROCEDURE AGAINST SG. THE ACPR ENFORCEMENT DIVISION 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 (HTTPS://ACPR.BANQUE-FRANCE.FR/EN/SANCTIONS/JURISPRUDENCE), 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 INVESTIGATION 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 HAD INCORRECTLY REPORTED ITS PROCESSING TIMES FOR SARS TO TRACFIN. Status: Final Sanction Detail: THE ACPR ENFORCEMENT COMMISSION ISSUED A REPRIMAND AGAINST SOCIETE GENERALE AND ORDERED IT TO PAY A FINE OF EUR 5 MILLION ($5,757,500 ACCORDING TO EXCHANGE RATE ON 7-19-17). Summary: THE ACPR ENFORCEMENT COMMISSION ISSUED A REPRIMAND AGAINST SOCIETE GENERALE AND ORDERED IT TO PAY A FINE OF EUR 5 MILLION ($5,757,500 ACCORDING TO EXCHANGE RATE ON 7-19-17).

Allegations: ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIETE GENERALE (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: ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $71,000 ASSESSMENT TO SOCIETE GENERALE (SG) FOR 71 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 ISSUED 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 SUBMISSIONS. Summary: ICE CLEAR ISSUED AN ASSESSMENT OF $71,000, 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 SOCIETE GENERALE 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 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 $10,000 ASSESSMENT TO SOCIETE GENERALE (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: SOCIETE GENERALE WAS THE SUBJECT OF AN ON-SITE EXAMINATION IN 2019 FROM THE BANQUE DE FRANCE (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 SOCIETE GENERALE 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 BANQUE DE FRANCE ORDERED SOCIÉTÉ GÉNÉRALE TO PAY A FINE OF EUR 62,379.60. FOR PURPOSES OF THIS FILING, SGAS CONVERTED THE FINE FROM EUR INTO USD BASED UPON A 1 EUR TO 1.134 USD EXCHANGE RATE AS OF FEBRUARY 22, 2002. Summary: THE BANQUE DE FRANCE ORDERED SOCIÉTÉ GÉNÉRALE TO PAY A FINE OF EUR 62,379.60. FOR PURPOSES OF THIS FILING, SGAS CONVERTED THE FINE FROM EUR INTO USD BASED UPON A 1 EUR TO 1.134 USD EXCHANGE RATE AS OF FEBRUARY 22, 2002.

Allegations: ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIETE GENERALE (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: 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 SOCIETE GENERALE ("SG") MAY HAVE VIOLATED EXCHANGE RULES 4.02(C) BY EXECUTING TRANSACTIONS 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-MINUTES 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: SG SETTLED THIS MATTER WITH ICE FUTURES U.S., INC. FOR A FINE OF $15,000.

Allegations: ICE CLEAR CREDIT LLC ("ICE CLEAR") ISSUED A $10,000 ASSESSMENT TO SOCIETE GENERALE (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 $1,000 ASSESSMENT TO SOCIETE GENERALE (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: ON NOVEMBER 19, 2018, SOCIETE GENERALE, S.A. ("SG") AND SOCIETE GENERALE 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 THE 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 CONSENT ORDER DESCRIBED SEVERAL DEFICIENCIES, INCLUDING ONES RELATED TO AML/BSA 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: ON NOVEMBER 19, 2018, SOCIETE GENERALE, S.A. ("SG") AND SOCIETE GENERALE 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 THE 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 CONSENT ORDER DESCRIBED SEVERAL DEFICIENCIES, INCLUDING ONES RELATED TO AML/BSA 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. Summary: ON NOVEMBER 19, 2018, SOCIETE GENERALE, S.A. ("SG") AND SOCIETE GENERALE 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 THE 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 CONSENT ORDER DESCRIBED SEVERAL DEFICIENCIES, INCLUDING ONES RELATED TO AML/BSA 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.

Allegations: ON NOVEMBER 19, 2018, SOCIETE GENERALE, S.A. AND SOCIETE GENERALE 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 U.S. SANCTIONS LAWS AND REGULATIONS IN A TIMELY MANNER. THE NYDFS FURTHER FOUND (I) 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.-SANCTIONS COUNTRIES; (II) 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 (III) THAT SG EXECUTED MORE THAN 2,600 OUTBOUND USD PAYMENTS, VALUED AT APPROXIMATELY $8.3 BILLION, IN VIOLATION OF APPLICABLE U.S. 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), A 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 GOVERNORS OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION). Status: Final Sanction Detail: ON NOVEMBER 19, 2018, SOCIETE GENERALE, S.A. AND SOCIETE GENERALE 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 U.S. SANCTIONS LAWS AND REGULATIONS IN A TIMELY MANNER. THE NYDFS FURTHER FOUND (I) 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.-SANCTIONS COUNTRIES; (II) 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 (III) THAT SG EXECUTED MORE THAN 2,600 OUTBOUND USD PAYMENTS, VALUED AT APPROXIMATELY $8.3 BILLION, IN VIOLATION OF APPLICABLE U.S. 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), A 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 GOVERNORS OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 Summary: ON NOVEMBER 19, 2018, SOCIETE GENERALE, S.A. AND SOCIETE GENERALE 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 U.S. SANCTIONS LAWS AND REGULATIONS IN A TIMELY MANNER. THE NYDFS FURTHER FOUND (I) 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.-SANCTIONS COUNTRIES; (II) 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 (III) THAT SG EXECUTED MORE THAN 2,600 OUTBOUND USD PAYMENTS, VALUED AT APPROXIMATELY $8.3 BILLION, IN VIOLATION OF APPLICABLE U.S. 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), A 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 GOVERNORS OF THE FEDERAL RESERVE SYSTEM (WITH A PENALTY OF $81.3 MILLION).

Allegations: DURING THE PERIOD FROM NOVEMBER 2007 TO FEBRUARY 2010, SOCIETE GENERALE IN THE UNITED KINGDOM (I) 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 (II) DID NOT RETAIN AND HAVE AVAILABLE SUCH TRADE REPORTING DATA, IN VIOLATION OF FSA RULES. Status: Final Sanction Detail: SOCIETE GENERALE WAS FINED 1.575 MILLION BRITISH POUNDS. Summary: SEE ABOVE

Allegations: THE FINANCIAL MARKET AUTHORITY (AMF) FINED SOCIETE GENERALE 500,000 EUROS FOR (I) 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 (II) BREACHING ARTICLES 321-24. 321-42, 321-43, 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 SOCIETE GENERAL 500,000.00 EUROS = $636,610.00 U.S. AS OF 11/7/2008 Summary: THE AMF FINED SOCIETE GENERAL 500,000.00 EUROS = $636,610.00 U.S. AS OF 11/7/2008

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 MONEY PENALTY AGAINST SOCIETE GENERALE, S.A. ("SG") WITH RESPECT TO THE FOLLOWING: (I) 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 THOUGH THE SG'S CORPORATE AND INVESTMENT BANKING OPERATIONS, COMPLIED WITH APPLICABLE REGULATIONS OF THE U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL ("OFAC"); AND (II) FROM AT LEAST 2007 TO 2012, AMONG OTHER THINGS, CERTAIN NON-US OFFICES, PRINCIPALLY SG IN FRANCE, PROCESSED U.S. DOLLAR-DENOMINATED FUNDS TRANSFERS THROUGH THE SG'S NEW YORK BRANCH AND THROUGH UNAFFILIATED U.S. FINANCIAL INSTITUTIONS INVOLVING PARTIES SUBJECT TO OFAC SANCTIONS THAT DID NOT CONTAIN RELEVANT INFORMATION WITHIN THE PAYMENT MESSAGES NECESSARY FOR THE U.S. FINANCIAL INSTITUTIONS TO DETERMINE WHETHER THESE TRANSACTIONS WERE CARRIED OUT IN A MANNER CONSISTENT WITH U.S. LAW, 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 U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTY 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: 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 MONEY PENALTY AGAINST SOCIETE GENERALE, S.A. ("SG") WITH RESPECT TO THE FOLLOWING: (I) 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 THOUGH THE SG'S CORPORATE AND INVESTMENT BANKING OPERATIONS, COMPLIED WITH APPLICABLE REGULATIONS OF THE U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL ("OFAC"); AND (II) FROM AT LEAST 2007 TO 2012, AMONG OTHER THINGS, CERTAIN NON-US OFFICES, PRINCIPALLY SG IN FRANCE, PROCESSED U.S. DOLLAR-DENOMINATED FUNDS TRANSFERS THROUGH THE SG'S NEW YORK BRANCH AND THROUGH UNAFFILIATED U.S. FINANCIAL INSTITUTIONS INVOLVING PARTIES SUBJECT TO OFAC SANCTIONS THAT DID NOT CONTAIN RELEVANT INFORMATION WITHIN THE PAYMENT MESSAGES NECESSARY FOR THE U.S. FINANCIAL INSTITUTIONS TO DETERMINE WHETHER THESE TRANSACTIONS WERE CARRIED OUT IN A MANNER CONSISTENT WITH U.S. LAW, 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 U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTY 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 MONEY PENALTY AGAINST SOCIETE GENERALE, S.A. ("SG") WITH RESPECT TO THE FOLLOWING: (I) 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 THOUGH THE SG'S CORPORATE AND INVESTMENT BANKING OPERATIONS, COMPLIED WITH APPLICABLE REGULATIONS OF THE U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL ("OFAC"); AND (II) FROM AT LEAST 2007 TO 2012, AMONG OTHER THINGS, CERTAIN NON-US OFFICES, PRINCIPALLY SG IN FRANCE, PROCESSED U.S. DOLLAR-DENOMINATED FUNDS TRANSFERS THROUGH THE SG'S NEW YORK BRANCH AND THROUGH UNAFFILIATED U.S. FINANCIAL INSTITUTIONS INVOLVING PARTIES SUBJECT TO OFAC SANCTIONS THAT DID NOT CONTAIN RELEVANT INFORMATION WITHIN THE PAYMENT MESSAGES NECESSARY FOR THE U.S. FINANCIAL INSTITUTIONS TO DETERMINE WHETHER THESE TRANSACTIONS WERE CARRIED OUT IN A MANNER CONSISTENT WITH U.S. LAW, 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 U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTY 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: FOLLOWING THE ANNOUNCEMENT ON JANUARY 24, 2008 BY SOCIETE GENERALE OF SIGNIFICANT LOSSES FROM CERTAIN UNAUTHORIZED TRADING ACTIVITY IN ITS PARIS OFFICE, THE FRENCH COMMISSION BANCAIRE REPRIMANDED AND FINED SOCIETE GENERAL 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 CURRENT VALUE OF THE FINE IN UNITED STATES DOLLARS. Summary: THE AMOUNT OF THE FINE WAS EURO 4 MILLION. THE $6 MILLION REFLECTED ABOVE IS THE APPROXIMATE CURRENT VALUE OF THE FINE IN UNITED STATES DOLLARS.

Allegations: WITHOUT ADMITTING ANY FINDINGS OF FAULT, SOCIETE GENERALE NEW YORK BRANCH AGREED TO PAY THE AMOUNT OF $111,359.00 IN CONNECTION WITH ALLEGATIONS THAT IT VIOLATED SECTIONS 560.206 AND 560.208 OF THE IRANIAN TRANSACTIONS REGULATIONS, 31C.F.R. PART 560, ON OR ABOUT DECEMBER 27, 2006, AND MAY 9, 2007. Status: Final Sanction Detail: SOCIETE GENERALE NEW YORK BRANCH AGREED TO PAY $111,359.00 FINE. Summary: SOCIETE GENERALE NEW YORK BRANCH AGREED TO PAY $111,359.00 FINE.

Allegations: ON NOVEMBER 19, 2018, SOCIETE GENERALE, S.A. ("SG"), ENTERED INTO A SETTLEMENT AGREEMENT WITH THE U.S. DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL ("OFAC") CONCERNING APPARENT VIOLATIONS OF U.S. 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 U.S. DOLLAR ("USD") TRANSACTIONS THROUGH U.S. FINANCIAL INSTITUTIONS TOTALING $5,560,452,994.36 THAT APPEAR TO HAVE VIOLATED THE FOLLOWING SANCTIONS PROGRAMS: THE CUBAN ASSETS CONTROL REGULATIONS, 31 C.F.R. PART 515; THE SUDANESE SANCTIONS REGULATIONS, 31 C.F.R. PART 538; AND THE IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS, 31 C.F.R. 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 U.S. 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 U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY 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, SOCIETE GENERALE, S.A. ("SG"), ENTERED INTO A SETTLEMENT AGREEMENT WITH THE U.S. DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL ("OFAC") CONCERNING APPARENT VIOLATIONS OF U.S. 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 U.S. DOLLAR ("USD") TRANSACTIONS THROUGH U.S. FINANCIAL INSTITUTIONS TOTALING $5,560,452,994.36 THAT APPEAR TO HAVE VIOLATED THE FOLLOWING SANCTIONS PROGRAMS: THE CUBAN ASSETS CONTROL REGULATIONS, 31 C.F.R. PART 515; THE SUDANESE SANCTIONS REGULATIONS, 31 C.F.R. PART 538; AND THE IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS, 31 C.F.R. 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 U.S. 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 U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY 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, SOCIETE GENERALE, S.A. ("SG"), ENTERED INTO A SETTLEMENT AGREEMENT WITH THE U.S. DEPARTMENT OF TREASURY'S OFFICE OF FOREIGN ASSET CONTROL ("OFAC") CONCERNING APPARENT VIOLATIONS OF U.S. 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 U.S. DOLLAR ("USD") TRANSACTIONS THROUGH U.S. FINANCIAL INSTITUTIONS TOTALING $5,560,452,994.36 THAT APPEAR TO HAVE VIOLATED THE FOLLOWING SANCTIONS PROGRAMS: THE CUBAN ASSETS CONTROL REGULATIONS, 31 C.F.R. PART 515; THE SUDANESE SANCTIONS REGULATIONS, 31 C.F.R. PART 538; AND THE IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS, 31 C.F.R. 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 U.S. 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 U.S. DEPARTMENT OF JUSTICE (WITH A PENALTY OF $717.2 MILLION), A DPA WITH THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE (WITH A PENALTY OF $162.8 MILLION), AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY 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: THE SECURITIES AND FUTURES COMMISSION ("SFC") ALLEGED THAT, IN OVER 3,000 TRANSACTIONS BETWEEN APRIL 2003 AND JANUARY 2006, SOCIETE GENERALE, 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, SOCIETE GENERALE AGREED TO ACCEPT A REPRIMAND FROM THE SFC AND TO REIMBURSE AFFECTED CUSTOMERS THE FULL VALUE OF THE ALLEGEDLY UNDISCLOSED FEES, TOGETHER WITH INTEREST. SOCIETE GENERALE 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. SOCIETE GENERALE 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 COMPLIANT WITH LEGAL AND REGULATORY REQUIREMENTS. Summary: WITHOUT ADMITTING LIABILITY, SOCIETE GENERALE AGREED TO ACCEPT A REPRIMAND FROM THE SFC AND REIMBURSE AFFECTED CUSTOMERS THE FULL VALUE OF THE ALLEGEDLY UNDISCLOSED FEES, TOGETHER WITH INTEREST. SOCIETE GENERALE 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. SOCIETE GENERALE 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 COMPLIANT WITH LEGAL AND REGULATORY REQUIREMENTS.

Allegations: SOCIETE GENERALE ENTERED INTO AN 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 RULES IN PLACE FOR ITS INVESTMENT RESEARCH AND ANALYSIS ACTIVITY, IN PARTICULAR, BY FAILING TO 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 UNDERTAKES TO: PAY THE PUBLIC TREASURY 450,000 EUROS EQUAL TO $526,410.00 U.S., 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 QUESTION, 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 UNDERTAKES TO: PAY THE PUBLIC TREASURY 450,000 EUROS EQUAL TO $526,410.00 U.S., 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 QUESTION, STRENGTHEN ITS PROCESSES FOR MANAGING INSIDE INFORMATION IN THE CONTEXT OF THE ACTAUDIT, 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.IVITY 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: 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 RULES IN FRANCE AND THAT CERTAIN OTHER FEES WERE NOT PROPORTIONATE TO COSTS INCURRED BY THE BANKS. THE PRIMARY PROCESSING FEES WERE CHARGED BETWEEN JANUARY 2002 AND JULY 2007. THE GROUP OF ELEVEN BANKS WAS FINED A TOTAL OF 384.92 MILLION EUROS. SOCIÉTÉ GÉNÉRALE WAS FINED 53.47 MILLION EUROS AND CREDIT DU NORD WAS FINED 6.98 MILLION EUROS. Status: On Appeal Sanction Detail: SOCIETE GENERALE WAS FINED 53.47 MILLION EUROS. CREDIT DU NORD WAS FINED 6.98 MILLION EUROS. 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 (KNOWN AS EIC - ÉCHANGE D'IMAGES CHÈQUES), 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 THE PARTICIPANTS TO THE AGREEMENT (INCLUDING THE BANQUE DE FRANCE) A TOTAL OF APPROXIMATELY EUR 385 MILLION. SOCIETE GENERALE WAS ORDERED TO PAY A FINE OF EUR 53.5 MILLION AND CRÉDIT 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 DE 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 SOCIETE GENERALE AND CRÉDIT DU NORD BY THE FRENCH COMPETITION AUTHORITY. ON 22 JANUARY 2018, SOCIETE GENERALE AND CRÉDIT DU NORD FILED AN APPEAL BEFORE THE SUPREME COURT AGAINST THIS DECISION. ON 29 JANUARY 2020, THE SUPREME COURT PARTIALLY QUASHED THE ORDER THE PARIS COURT OF APPEAL DECISION OF 21 DECEMBER 2017 AND ORDERED THE REMAND OF THE CASE TO THIS SAME COURT OF APPEAL BUT DIFFERENTLY COMPOSED. ON 13 MARCH 2020, SOCIETE GENERALE AND CRÉDIT DU NORD THEREFORE FILED A NEW APPEAL BEFORE THE PARIS COURT OF APPEAL AGAINST THE DECISION OF THE FRENCH COMPETITION AUTHORITY. THE COURT PROCEEDING IS STILL PENDING.

Allegations: CFTC ALLEGED THAT FROM APPROXIMATELY 2013 TO JULY 2021, SOCIETE GENERALE S.A. ("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 DAILY MARKS AND REPORTED INACCURATE SWAP VALUATION DATA TO AN SDR. FINALLY, SG FAILED TO DISCLOSE PRE-TRADE MID-MARKET MARKS (PTMMMS) TO COUNTERPARTIES OVER CERTAIN ELECTRONIC TRADING PLATFORMS. THE ISSUES WERE SELF-REPORTED TO CFTC, AND THE ORDER PROVIDED FOR A SUBSTANTIALLY 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: WITHOUT ADMITTING OR DENYING THE ALLEGED RULE VIOLATIONS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS.

Allegations: THE COMMISSION FOUND THAT SOCIETE GENERALE ("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 4R(A)(3)OF THE ACT, 7 U.S.C.§§ 2(A)(13)(F),(G), 6R(A)(3)(2012), AND REGULATIONS 43.3(A)(3), 43.4(A), 45.3(C)(1) AND 45.4(A), 17 C.F.R. §§ 43.3(A)(3), 43.4(A), 45.3(C)(1) AND 45.4(A)(2016). Status: Final Sanction Detail: SG AGREED TO A FINE OF $450,000.00 AND WAS ORDERED TO CEASE & DESIST FROM FUTURE VIOLATIONS. Summary: THE COMMISSION FOUND THAT SOCIETE GENERALE ("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 4R(A)(3)OF THE ACT, 7 U.S.C.§2(A)(13)(F),(G), 6R(A)(3)(2012), AND REGULATIONS 43.3(A)(3), 43.4(A), 45.3(C)(1) AND 45.4(A), 17 C.F.R. §§ 43.3(A)(3), 43.4(A), 45.3(C)(1) AND 45.4(A)(2016).§

Allegations: ON JUNE 4, 2018, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ENTERED AN ORDER (THE "ORDER") INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C) AND 6(D) OF THE COMMODITY EXCHANGE ACT (THE "CEA"), FINDING THAT, DURING THE PERIOD OF 2006 THROUGH MID-2012, SOCIÉTÉ GÉNÉRALE S.A. ("SOCIÉTÉ GÉNÉRALE"), BY AND THROUGH CERTAIN TRADERS AND CERTAIN MEMBERS OF MANAGEMENT, COMMITTED ACTS OF ATTEMPTED MANIPULATION AND/OR ACTUAL MANIPULATION OF, AND MADE FALSE, MISLEADING OR KNOWINGLY INACCURATE REPORTS OF MARKET INFORMATION IN CONNECTION WITH, THE LONDON INTERBANK OFFERED RATE ("LIBOR") FOR U.S. 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. SOCIÉTÉ GÉNÉRALE WIRED THIS PAYMENT ON JUNE 13, 2018, AND THE CFTC CONFIRMED RECEIPT AS OF JUNE 14, 2018. Summary: SOCIÉTÉ GÉNÉRALE, WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR CONCLUSIONS, EXCEPT TO THE EXTENT THAT IT ADMITTED THOSE FINDINGS IN ANY RELATED ACTION AGAINST IT BY, OR ANY AGREEMENT WITH, THE U.S. DEPARTMENT OF JUSTICE OR ANY OTHER GOVERNMENTAL AGENCY OR OFFICE, CONSENTED TO THE ENTRY OF THE ORDER. THE FINDINGS MADE AND SANCTIONS IMPOSED UNDER THE ORDER ARE NOTED ABOVE.

Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ENTERED INTO A SETTLEMENT ORDER ("ORDER") WITH SG AMERICAS SECURITIES, LLC ("SGAS") AND SOCIÉTÉ GÉNÉRALE SA ("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 SECTIONS 4S(F)(1)(C) AND 4S(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 VIOLATION 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, ACKNOWLEDGED 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 VIOLATING 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 VIOLATING SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35 AND 166.3, (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: ON AUGUST 8, 2023, THE CFTC ENTERED INTO AN ORDER WITH THE RESPONDENTS TO SETTLE AN ADMINISTRATIVE ACTION CONCERNING (A) SOCIÉTÉ GÉNÉRALE'S FAILURE TO MAINTAIN REQUIRED RECORDS IN VIOLATION OF SECTIONS 4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE 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 VIOLATION 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. THE RESPONDENTS ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED 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 VIOLATING 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 VIOLATING SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35 AND 166.3, (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.