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