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

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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 Notes as more business critical than a corporate compliance program. ....

New York , United States , Spencer Silver , Stephen Martin , Mike Volkov , New York Times , Department Of Justice , Compliance Program Framework , Post It Notes , Post It Note , Non Prosecution Agreement , Foreign Corrupt Practices Act , Voluntary Self Disclosure , Sanctions Enforcement Policy , Export Control Team , Senior Management Commitment , Risk Assessment , Internal Controls , Export Control , Chief Compliance Officer , Business Conduct , புதியது யார்க் , ஒன்றுபட்டது மாநிலங்களில் , ஸ்பென்சர் வெள்ளி , ஸ்டீபன் மார்டின் , புதியது யார்க் முறை ,

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

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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 pushes DOJ’s views and expectations for export control and sanctions compliance programs. Like the past history of enforcement actions and compliance program requirements involving the FCPA, DOJ’s SAP settlement is the beginning of a new, aggressive approach to export and sanctions compliance standards beyond those required by OFAC and BIS. ....

North Korea , Cloud Business Group , While The Justice Department National Security Division , Volkov Law Group , Volkov Law , Justice Department , National Security Division , North Korea Sanctions , Export Control , Sanctions Enforcement Policy , Business Organizations , Export Control Team , Business Group , வடக்கு கொரியா , மேகம் வணிக குழு , நீதி துறை , தேசிய பாதுகாப்பு பிரிவு , ஏற்றுமதி கட்டுப்பாடு , வணிக ஆர்கநைஸேஶந்ஸ் , வணிக குழு ,