Tagged: Export and sanctions compliance

The Headline from the SAP Settlement: It’s a New Dawn for Export and Sanctions Compliance (Part IV of IV)

The Department of Justice’s National Security Division, like its counterpart, the Criminal Division, has made a splash on the enforcement and compliance arena. DOJ has elevated the importance and standing of export and sanctions enforcement to make one message clear – DOJ will hold companies accountable for criminal violations of U.S. export and sanctions laws.  And it will do so with the carrot and stick...

SAP’s Comprehensive Export Control and Sanctions Settlement – A New Compliance Frontier for Cloud-Based Services (Part III of IV)

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...