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When will the next compliance crisis occur? As we learned from the recent SAP trade sanction enforcement action, it can be quite some time from a change which leads to a violation that leads to an enforcement action. In this case for SAP, it was acquisitions in the early 2010s, who had violations from 2010 to 2017, that led to the 2021 enforcement action. Foreign Corrupt Practices Act (FCPA) enforcement actions can have an equally long, if not longer, number of years where a series of unfortunate events can lead to costly investigations and enforcement actions.