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

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, it provided numerous lessons for all compliance professionals. I want to explore the issue of post-...

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

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 settlements highlight many of those risks, such as the reliance on third-party resellers, the integration of...