Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into SAP trade sanction enforcement action. Some of the issues we consider are:
What were the underlying facts?
How did SAP allow products to get to Iran for so long?
How did SAP achieve a NPA even with aggrieved factors?
How was the financial penalty calculated?
What were the remedial steps SAP engaged in?
Why does this enforcement action point towards the need for a more holistic approach to risk?
Resources
Matt’s blog post on Radical Compliance:
SAP Nailed on Sanctions Violations
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