SAP agreed to a three-year deferred prosecution agreement, in exchange for the payment of approximately $220 million in penalties for bribe payments made to South African and Indonesia government officials. DOJ’s resolution includes a criminal penalty of $118.8 million and forfeiture of $103.4 million, along with a credit of $55.1 million against amounts paid by SAP to South African law enforcement authorities, and the full forfeiture amount against disgorgement SAP pays to the SEC or South African authorities. DOJ decided not to impose an independent compliance monitor.
In this Episode, Michael Volkov reviews the SAP settlement, the underlying bribery schemes and lessons learned.
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