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?


Matt’s blog post on Radical Compliance:

 SAP Nailed on Sanctions Violations