Compliance into the Weeds SAP Trade Sanctions Enforcement Action
May 5, 2021
23:07
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into SAP trade sanction enforcement action. Some of the issues we consider are:
- What were the underlying facts?
- How did SAP allow products to get to Iran for so long?
- How did SAP achieve a NPA even with aggrieved factors?
- How was the financial penalty calculated?
- What were the remedial steps SAP engaged in?
- Why does this enforcement action point towards the need for a more holistic approach to risk?
Resources
Matt’s blog post on Radical Compliance:
SAP Nailed on Sanctions Violations
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