Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls (Part III of III)
A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you. I know I am scratching my head trying to make sense of the whole picture here. There are a number of significant indicators of a change in DOJ’s tack, along with SEC’s aggressive push on third-party controls. DOJ’s position is even more difficult to understand as explained below....
