Defendant Name: SAP SE

Defendant Type: Public Company
SIC Code: 7372
CUSIP: 80305420

Initial Case Details

Legal Case Name In the Matter of SAP SE
First Document Date 01-Feb-2016
Initial Filing Format Administrative Action
File Number 3-17080
Allegation Type Foreign Corrupt Practices Act
AAER 3736

Violations Alleged

Exchange Act
Sec 13(b)(2)(A)
Sec 13(b)(2)(B)


First Resolution Date 01-Feb-2016
Headline Total Penalty and Disgorgement

See Related Documents

Related Documents:

2016-17 01-Feb-2016 Press Release--Administrative Proceeding
SEC Charges Software Company with FCPA Violations
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."
34-77005 01-Feb-2016 Administrative Proceeding
Order Instituting Cease-and-Desist Proceedings, Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order
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."

Related Actions:

In the Matter of Vicente E. Garcia