On February 1, 2016, the SEC announced that "software manufacturer SAP SE has agreed to give up $3.7 million in sales profits to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) when procuring business in Panama."

On February 1, 2016, the SEC instituted settled cease-and-desist proceedings against SAP SE. According to the SEC: "This matter concerns violations of the books and records and internal controls provisions of the Foreign Corrupt Practices Act of 1977 ('FCPA') by SAP SE ('SAP'), a European Union corporation headquartered in Waldorf, Germany. The violations occurred due to deficient internal controls, which allowed SAP's former Vice-President of Global and Strategic Accounts, Vicente E. Garcia, to discount the software price to a former SAP local partner at a level sufficient to permit Garcia and the local partner to pay $145,000 in bribes to one senior Panamanian government official, and offer bribes to two others. Through these bribes, Garcia secured government sales contracts of approximately $3.7 million for SAP, and also self-profited through kickbacks. By excessively discounting the SAP software, Garcia created a slush fund that the partner used to pay the bribes and kickbacks. Garcia concealed his scheme from others at SAP, circumvented SAP's internal controls, and justified the excessive discounts by falsifying SAP's internal approval forms." The SEC stated that it was not imposing a civil penalty on SAP SE due to SAP SE's "cooperation in a Commission investigation and related enforcement action."