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

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 would set the tone for rest of the negotiations. The bottom line was that the company viewed Post-It N...

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

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 important insights into DOJ’s export control and sanctions compliance expectations. The SAP case p...