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Stephen Martin would often tell the story about when he was a Department of Justice (DOJ) prosecutor and a company would come in and claim they spent all the money they could on their corporate compliance program. Martin would then ask, “How much did you spend last year on Post-It Notes?” The answer was always four to five times the amount of their annual compliance budget. This immediately put the company back on its heels and would set the tone for rest of the negotiations. The bottom line was that the company viewed Post-It Notes as more business critical than a corporate compliance program.
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The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – a loud and clear one.
As the first real flexing of its Business Organizations Corporate Enforcement policy, the Justice Department underscored that companies that voluntarily disclose illegal conduct, fully cooperate, and implement timely and robust remediation will earn a non-prosecution agreement or deferred prosecution agreement and a significant reduction in corporate fines.
SAP’s illegal conduct was broad, systemic and covered a long period – at least seven years. SAP knew that the illegal conduct was occurring through direct sales and indirect third-party reseller sales. Indeed, SAP ignored or delayed several audit findings and recommendations to institute compliance measures, improve its compliance programs, and increase resources and compliance tech