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1. Recent Enforcement: Even Companies That Invest in Compliance Pay Penalties Since our April enforcement roundup, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) in the Department of Commerce have issued several important penalty announcements. These enforcement actions demonstrate that even multinational companies that invest in compliance can run into problems without a continued commitment to monitoring and updating their programs. Global software company SAP SE paid a total of $8 million in a combined global resolution with the Department of Justice (DOJ), Commerce, and Treasury for illegal exports, and it also disgorged $5.14 million in profits. Between December 2009 and September 2019, the company exported its software, upgrades, and patches more than 20,000 times to end users in sanctioned countries, including Iran, without a license. As part of the settlement, SAP must perform three internal audits of its export compliance program

North koreaUnited statesBureau of prisonsBitgo incCommittee on foreign investmentServices supply chain commerceNational defense authorizationMultilateral telecommunications security fundOffice of foreign assets controlMoneygram payment systems incDepartment of justiceCommunications technologyCommerce issues subpoenas under new technology authorityPublic wireless supply chain innovation fundDepartment of commerceBureau of industry