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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, “How much did you spend last year on Post-It Notes?” 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

The SAP Enforcement Action: The Need for Robust and Timely Post-Acquisition Integration | Thomas Fox

To embed, copy and paste the code into your website or blog: The SAP enforcement action was certainly a game-changer in trade sanction enforcement. It was the first Justice Department (DOJ) National Security Section enforcement action under the under the Justice Department’s Export Control and Sanctions Enforcement Policy. Mike Volkov, channeling his inner Grace Slick, called it “a New Dawn”. Moreover, although the enforcement action was in the realm of export control and trade sanctions,...
New York United States Tom Pannell Mike Volkov Matt Kelly Grace Slick

SPACE-TIME POLITICS

simulating reentry velocities and conditions with a three-stage solid-fuel Lockheed X-17. A total of 26 X-17 flights were conducted until March 1957. 1958 Aug 27 -Launch Site USS Norton Sound Launch Complex Argus 1 The Argus series were the only clandestine nuclear ever conducted by the United States.The rocket-launched nuclear warheads were set off at very high altitudes over the South Atlantic,1800 km south-west of Capetown,South Africa. The purpose was to determine the effects of nuclear tes...
Air Base United States France General United Kingdom Pearl Harbor San Diego

Jury Convicts Iranian National for Illegally Exporting Military Sensitive Items

Jury Convicts Iranian National for Illegally Exporting Military Sensitive Items Posted on WASHINGTON – A federal jury convicted an Iranian citizen and a resident of the United Arab Emirates and Germany, for scheming to obtain military sensitive parts for Iran in violation of the Iranian Trade Embargo. These parts had dual-use military and civilian capability and could be used in systems such as nuclear weapons, missile guidance and development, secure tactical radio communications, offensive...
United Arab Emirates United States Susan Yip Kelly Stevenson Mark Roomberg Williamr Harris

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs | WilmerHale

To embed, copy and paste the code into your website or blog: On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The companies, MoneyGram Payment Systems, Inc. (MoneyGram) and SAP SE (SAP), operate in sectors of the economy—payments and software—that present unique sanctions risks and compliance challenges. The two settleme...
United States United Arab Emirates Bitpay Inc Us Department Of Commerce Bureau Industry Bureau Of Prisons Us Department Of Justice

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SAP Admits to Illegal Software Exports to Iran

SAP Admits to Illegal Software Exports to Iran 3 weeks ago SAP entered into an agreement with the Department of Justice (DOJ), admitting it illegally exported thousands of copies of its software to Iran. SAP is the one of the leading enterprise software companies in the world, with a focus on ERP, cloud and IoT solutions. The company does business all over the world, requiring it to adhere to the laws and regulations of the many countries it operates within. Unfortunately, the company has ru...
Josephr Bonavolonta Johnc Demers Department Of Justice Department Export Justice Department National Security Division Boston Division

China issued Export Compliance Guidelines for dual-use items | Dentons

On April 28, 2021, Ministry of Commerce (MOFCOM) issued Announcement No. 10 " Guiding Opinions of Ministry of Commerce on Establishing the Internal Compliance Program for Export Control by Exporters of Dual-use Items" (the “Compliance Guideline”). The Compliance Guideline substitutes the previous 2007 MOFCOM opinions and provides specific guidelines and suggestions for exporters to establish export compliance programs as the Export Control Law became effective on December 1, 2020. Scope of ...
Bureau Of Industry Ministry Of Commerce Us Department Of Commerce Internal Compliance Program Export Control Compliance Guideline

Mercedes-Benz Reveals Two New EQA AWD Models Ready For Sale

Mercedes-Benz Reveals Two New EQA AWD Models Ready For Sale Stuttgart. May 5, 2021; Mercedes-Benz says that more than 20,000 customers have already ordered an EQA since February. Now two new members are joining the model family of the all-electric compact SUV: the EQA 300 4MATIC with 168 kW (combined power consumption: 15.8 kWh/100 km, CO 2 emissions: 0 g/km) [1] and the EQA 350 4MATIC with 215 kW (combined power consumption: 15.8 kWh/100 km, CO 2 emissions: 0 g/km)1 round off the line-up at th...
Mercedes Benz Bank Parts Centre Office For Economic Affairs Mercedes Benz Reveals Two New Ready For Benz Bank

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV) | Michael Volkov

To embed, copy and paste the code into your website or blog: While the Justice Department’s National Security Division (“NSD”) has settled prior export control and sanctions cases against corporations for violations of the North Korea Sanctions program, the SAP case is the first in which DOJ’s NSD flexed its new Export Control and Sanctions Enforcement Policy for Business Organizations, by crediting voluntary disclosure, cooperation and remediation. Further, the SAP settlement provides ...
North Korea Cloud Business Group While The Justice Department National Security Division Volkov Law Group Volkov Law Justice Department

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