Software manufacturer SAP SE will disgorge $3.7 million from profits on its sales of software to the Panamanian Government to settle charges that it violated the Foreign Corrupt Practices Act when procuring business in Panama. An SEC investigation found that SAP’s deficient internal controls allowed a former SAP executive, Vincente Garcia, to pay $145,000 in bribes to a senior Panamanian government official and offer bribes to two others in exchange for lucrative software contracts. The bribery scheme involved providing large discounts of up to 82% to SAP’s Panamanian business partner, who used the excessive discounts to create a slush fund out of which it could pay bribes on Garcia’s behalf. SEC
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