This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more
The Securities and Exchange Commission’s (SEC) recent Foreign Corrupt Practices Act (FCPA) settlements focus on companies’ lack of sufficient anti-corruption compliance programs, which means, to the SEC, that the companies...more
The SEC filed another settled FCPA proceeding in which cooperation substantially mitigated the sanctions. Specifically, a monetary penalty was not imposed on the firm in view of its cooperation, although the company did not...more