SAP Enforcement Action Underscores Importance of Ensuring Compliance Programs Address Considerations Associated with Business Partners and Identified Compliance Gaps

The Office of Foreign Assets Control of the Department of Treasury, and the Bureau of Industry and Security of the Department of Commerce announced settlements with German software company SAP, SE to resolve violations of the Iranian Transactions and Sanctions Regulations, and the Export Administration Regulations stemming from SAP’s exportation of software and software services—through third-party resellers—to end-users in Iran.