Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Jay Rosen who discusses the recent FCPA enforcement action involving the software giant SAP.
Jay Rosen is a seasoned compliance professional with a deep understanding of the SAP FCPA enforcement case. His perspective on the topic of SAP’s FCPA enforcement case and the importance of cooperation and self-disclosure is shaped by his belief that self-disclosure is paramount in any FCPA investigation or enforcement action. He points out that SAP did not initially self-disclose, but began to cooperate only after investigative reports were made public in South Africa. Despite this, Rosen acknowledges SAP’s commendable efforts in providing regular, prompt, and detailed updates to the fraud section, producing relevant documents, and undertaking extensive remediation actions. He underscores the importance of conducting a root cause analysis, implementing data analytics, and enhancing compliance programs and internal controls, asserting that companies can recover if they follow these steps and use data-driven analytics to counterbalance any negative facts. Join Tom Fox and Jay Rosen as they delve deeper into this topic on this episode of the FCPA Compliance Report.
Key Highlights:
- The facts and underlying bribery schemes
- Lack of self-disclosure and what it means
- Extensive cooperation
- Extensive remediation
- A superior result achieved
Resources:
Jay Rosen on LinkedIn
Tom Fox
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