Defendant Name: SAP SE

Defendant Type: Public Company

Document Reference: 2024-4

Document Details

Legal Case Name In the Matter of SAP SE
Document Name SEC Charges Global Software Company SAP for FCPA Violations; German multinational agrees to monetary sanctions of nearly $100 million to settle SEC's bribery charges
Document Date 10-Jan-2024
Document Format Administrative Proceeding
File Number 3-21824
Allegation Type Foreign Corrupt Practices Act
Document Summary On January 10, 2024, the SEC "announced charges against global software company SAP SE for violations of the Foreign Corrupt Practices Act (FCPA) arising out of bribery schemes in South Africa, Malawi, Kenya, Tanzania, Ghana, Indonesia, and Azerbaijan. The company agreed to monetary sanctions of nearly $100 million in disgorgement and prejudgment interest to settle the SEC's charges."

Disgorgement & Penalty Information

Resolutions
Cease and Desist Order
The SEC stated that the disgorgement and prejudgment interest "will be offset by up to $59 million paid by SAP to the South African government in connection with its parallel investigations into the same conduct."
Monetary Penalties:

Disgorgement

Individual:     $85,000,000.00 Shared:    

Pre-Judgment Interest

Individual:     $13,400,000.00 Shared:    

Total Penalty

Individual:     $98,000,000.00 Shared:    

Related Documents:

34-99308 10-Jan-2024 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 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."