German software company discloses possible FCPA and US sanctions violations

SAP SE, an enterprise management software company headquartered in Germany, reported that it is investigating allegations from a whistleblower and others of possible violations of anti-bribery laws in South Africa.  The company voluntarily disclosed the allegations and investigation to the US Securities and Exchange Commission, the Department of Justice, and South African authorities.  Since the allegations came to light, the company reports, it has implemented more robust internal controls, appointed new management in certain business units, increased the number of compliance personnel, undertaken a systematic review of relationships with state-owned entities and institutions throughout Africa, and banned the use of commissioned business development partners and agents in high risk markets.

SAP reported that it also voluntarily self-disclosed potential violations of US sanctions to the Office of Foreign Assets Control, the DOJ, and the Bureau of Industry and Security, and has filed an Iran Notice with the SEC pursuant to Section 219 of the US Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the US Securities Exchange Act of 1934.  The company said that it has also enhanced its export controls compliance by adding due diligence measures and increasing the capacity of its export controls compliance team.

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