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SAP SE (“SAP”), a global software company headquartered in Walldorf, Germany, has agreed to pay a total of $8.43 million in penalties as part of settlement agreements with the United States Departments of Justice, Commerce and Treasury, a penalty that would have significantly higher if the company had not extensively cooperated with the United States. Involuntary disclosures to all three agencies, SAP acknowledged that, from January 2010 through September 2017, it knowingly released more than 25,000 downloads of its products, upgrades and/or patches from its U.S. Headquartered Content Delivery Provider to Iranian users in violation of the Export Administration Regulations (“EAR”) and the Iranian Transactions and Sanctions Regulations (“ITSR”). Many of the downloads were associated with sales by non-SAP entities (“SAP Partners”) or the activities of SAP customers headquartered outside of Iran but had used
SAP Admits To Thousands Of Illegal Exports To Iran Under NPA: Lessons Learned - International Law mondaq.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from mondaq.com Daily Mail and Mail on Sunday newspapers.
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On April 29, 2021, the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the District of Massachusetts (collectively, “
DOJ”) announced that DOJ entered into a precedent-setting non-prosecution agreement with German software company SAP SE (“
SAP”) for more than $8 million, after it became the first company to voluntarily disclose U.S. export and sanctions violations pursuant to DOJ’s new export control and sanctions voluntary self-disclosure (“
VSD”) policy. Although SAP was required to disgorge $5.14 million of ill-gotten gains, DOJ did not prosecute SAP nor seek any additional penalty amount. The resolution – which carefully tracks the National Security Division’s 2019 VSD policy (on which we have written before) – provides a roadmap for how companies can obtain full voluntary self-disclosure credit, and a case study of when DOJ will eschew criminal
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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 settlements highlight many of those risks, such as the reliance on third-party resellers, the integration of newly acquired companies, and contracting with the US government. They are part of a trend of increased OFAC enforcement
SAP legt Streit mit US-Behörden um Software-Verkäufe an Iran bei silicon.de - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from silicon.de Daily Mail and Mail on Sunday newspapers.