Posts Tagged ‘SAP’
SAP’s Non-Monitor Monitorship
Here’s a rather odd item in the annals of FCPA enforcement: software giant SAP recently assigned one of its internal compliance employees to be the company’s “monitorship compliance officer” — for an FCPA settlement announced in January that didn’t require a compliance monitor. This came to my attention when the SAP employee announced on LinkedIn…
Read MoreA Tale of Two Monitor Decisions
One dreaded outcome from a regulatory investigation is the appointment of an independent compliance monitor. Now two recent corporate misconduct settlements demonstrate how puzzling regulators’ decisions about compliance monitors can be — because for the life of me, I can’t figure out why one company received a monitor while the other didn’t. The cases involve…
Read MoreSAP, Part II: Remediation Work
Today, let’s return to the FCPA enforcement action announced last week against German software giant SAP, which resulted in $220 million in penalties and disgorgement, plus a long list of compliance remediation measures. Those measures are worth going through in detail. For those who missed last week’s news, the recap is as follows. SAP agreed…
Read MoreSAP Pays $220M on FCPA Violations
German software giant SAP is paying $220 million and implementing a raft of reforms to settle FCPA violations in seven countries, in a case with lessons about the importance of internal audits to root out misconduct and about structural reforms regulators want to see to prevent repeat offenses. The Justice Department and Securities and Exchange…
Read MoreSAP, Part II: The Gritty Compliance Details
Today we return to that enforcement action imposed on business software giant SAP, which last week settled charges that it had violated U.S. export control law in the 2010s by offering software patches, upgrades and cloud-based services to users in Iran. Our first post on the case was more a summary of the overall facts,…
Read MoreSAP Nailed on Sanctions Violations
Software firm SAP is paying $13.1 million to settle charges that the company and its business partners violated U.S. sanctions law in the 2010s by offering software patches and upgrades to users in Iran and allowing Iranian customers access to SAP’s cloud-based technology services. The settlement was announced Thursday by the U.S. Justice Department, along…
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