Defendant Name:
SAP SE
Defendant Type:
Public Company
SIC Code:
7371
CUSIP:
80305420
Document Reference:
34-99308
Document Details
Legal Case Name
In the Matter of SAP SE
Document Name
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
Document Date
10-Jan-2024
Document Format
Administrative Proceeding
AAER
4481
Allegation Type
Foreign Corrupt Practices Act
Document Summary
On January 10, 2024, the SEC instituted settled cease-and-desist proceedings against SAP SE, stating: "This matter concerns SAP’s violations of the anti-bribery, books and records, and
internal accounting controls provisions of the Foreign Corrupt Practices Act (the “FCPA”). SAP is
a global software company headquartered in Walldorf, Germany. From at least December 2014
through December 2018, SAP employed third-party intermediaries and consultants in various
schemes to make improper payments to government officials in order to obtain and retain business
in South Africa, Greater Africa (Malawi, Kenya, Tanzania, and Ghana), and Indonesia.
Additionally, an SAP Azerbaijan employee provided improper gifts to a government official in
order to obtain and retain business in Azerbaijan in January 2022."
Disgorgement & Penalty Information
Resolutions
Cease and Desist Order
The Commission ordered that: "Respondent shall receive a disgorgement offset of up to $59,455,779 based on the U.S. dollar value (based on the exchange rate on the date of the payment) of any payments made or to be made to the Government of South Africa or a South African state-owned entity."
Cooperation Before the Resolution
Remedial Acts or Efforts Before the Resolution
Self Reporting to SEC
Monetary Penalties:
Disgorgement
Individual:
$85,046,035.00
Shared:
Pre-Judgment Interest
Individual:
$13,405,149.00
Shared:
Total Penalty
Individual:
$98,451,184.00
Shared:
