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Podcast: Corruption Crime & Compliance
Episode: Episode 192 -- The SAP Settlement: A New Compliance Frontier
Description: In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program.
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, crediting voluntary disclosure, cooperation and remediation. Further, the SAP settlement provides important insights into DOJ’s export c...