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 | Investigations Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Investigations Dataset

 
Investigation into SAP's Activities in Multiple Countries · SAP SE

Information & Summary

Investigation into SAP's Activities in Multiple Countries

Related FCPA Matter:   SAP's Involvement in Multiple Countries from 2014 to 2022 Information

Information & Summary

Investigation Name:    Investigation into SAP's Activities in Multiple Countries

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:   

  • South African Law Enforcement Agency

Whistleblower:    Yes

Summary

SAP SE (“SAP”) was a European Union corporation headquartered in Waldorf, Germany. SAP’s American Depositary Shares were registered with the SEC pursuant and listed on the New York Stock Exchange. SAP markets its software all over the world through various country subsidiaries.

In its 20-F filed on February 28, 2018, SAP disclosed that it had initiated an internal investigation with the assistance of outside counsel into alleged conduct that might violate the FCPA. SAP advised local authorities as well as the DOJ and SEC about the internal investigation.

According to the same filing, the DOJ and SEC then began their own investigations into the alleged misconduct, and SAP said it was cooperating with both agencies' investigations.

In its 20-F filed on February 28, 2019, the company confirmed that it had received whistleblower information about the misconduct, and it further disclosed that the misconduct may have violated South African anti-bribery laws, which suggest that the misconduct potentially occurred there.

In its 6-K filed on July 24, 2019, SAP disclosed that it had also received communications about possible misconduct that additionally violated anti-bribery laws in Brazil and Indonesia.

In its 6-K filed on July 25, 2023, SAP disclosed that it had accrued €170 million in anticipation of a possible settlement.

On January 10, 2024, the DOJ and SEC announced enforcement actions against SAP.

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