Ten Takeaways From SAP’s Recent Export Controls and Economic Sanctions Settlement Agreements
In this article for Thomson Reuters' Westlaw Today, Kirkland attorneys Mario Mancuso, Sanjay Mullick, Anthony Rapa and Abigail Cotterill discuss penalties faced by SAP SE for violations of U.S. export controls and economic sanctions. Though significant, the penalties were mitigated by SAP being the first company to avail itself of DOJ’s Export Control and Sanctions Enforcement Policy for Business Organizations.
"...SAP filed voluntary self-disclosures with DOJ, BIS, and OFAC, resulting in reduced penalties as well as a Non-Prosecution Agreement with DOJ. The settlements offer several important lessons for technology companies conducting global transactions."
