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Post It Notes and the SAP Non-Prosecution Agreement | Thomas Fox

To embed, copy and paste the code into your website or blog: Stephen Martin would often tell the story about when he was a Department of Justice (DOJ) prosecutor and a company would come in and claim they spent all the money they could on their corporate compliance program. Martin would then ask, โ€œHow much did you spend last year on Post-It Notes?โ€ The answer was always four to five times the amount of their annual compliance budget. This immediately put the company back on its heels and wo...
New York United States Spencer Silver Stephen Martin Mike Volkov New York Times

SAP's Comprehensive Export Control and Sanctions Settlement – A New Compliance Frontier for Cloud-Based Services (Part III of IV) | Michael Volkov

To embed, copy and paste the code into your website or blog: The Justice Departmentโ€™s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message โ€“ a loud and clear one. As the first real flexing of its Business Organizations Corporate Enforcement policy, the Justice Department underscored that companies that voluntarily disclose illegal conduct, fully cooperate, and implement timely and robust remediation will earn a non-pro...
Justice Department Justice Department National Security Division Volkov Law Group Compliance Program Framework Party Business Partner Notification Volkov Law

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