Vicente E. Garcia, a former vice president for SAP SE, agreed to pay $92,395 to settle charges by the SEC that he violated the FCPA by bribing Panamanian government officials to procure software license sales for SAP. An SEC investigation found that Garcia orchestrated a scheme to pay $145,000 in bribes to one government official and promised to pay two others in order to obtain four contracts to sell SAP software to the Panamanian government. Garcia arranged for SAP’s software to be sold at a steep discount to a Panamanian partner in order to create a slush fund that could be used to pay the Panamanian government officials. Garcia also received kickbacks from the slush fund. In a parallel action, the Department of Justice announced a criminal action against Garcia. SEC
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