January 10, 2024

German software company SAP SE (SAP) has agreed to pay over $220 million and enter into a three-year deferred prosecution agreement with the DOJ to resolve allegations of violating the Foreign Corrupt Practices Act (FCPA) by paying bribes to government officials in Azerbaijan, Ghana, Indonesia, Kenya, Malawi, South Africa, and Tanzania from at least 2014 to 2022.  The company allegedly paid third parties to pay the bribes, then recorded the bribes as legitimate business expenses in its books and records.  To resolve parallel investigations with other authorities, SAP has agreed to pay almost $100 million to the SEC, which will be offset by a $59 million payment already made to the South African government.  DOJ; SEC

Tagged in: Bribery and Bid-Rigging, FCPA,