To embed, copy and paste the code into your website or blog: The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – 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-prosecution agreement or deferred prosecution agreement and a significant reduction in corporate fines. SAP’s illegal conduct was broad, systemic and covered a long period – at least seven years. SAP knew that the illegal conduct was occurring through direct sales and indirect third-party reseller sales. Indeed, SAP ignored or delayed several audit findings and recommendations to institute compliance measures, improve its compliance programs, and increase resources and compliance technologies needed to support an effective program. Notwithstanding all of these problems, DOJ cited SAP’s voluntary disclosure in 2017, its full cooperation, and its remediation and compliance improvements.