Non-Prosecution Agreement (Agreement) - SAP SE

Date issued: Apr. 19 2021

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TURBOFAC Commentary (228 words)

Notes:

1) Refer to Civil Enforcement Information - SAP SE for consolidated comment on the SAP Global Settlement. The items in the Research System that relate to the SAP case are the following:

(i) Civil Enforcement Information - SAP SE
(ii) Settlement Agreement (BIS) - SAP SE
(iii) Non-Prosecution Agreement (Agreement) - SAP SE
(iv) Non-Prosecution Agreement (Statement of Facts) - SAP SE

2) Compare Department of Justice Export Control and Sanctions Enforcement Policy for Business Organizations (Dec. 2019 - First Reissuance). This appears to be the first NPA entered into by the DOJ pursuant to the "VSD Policy" set out in that document. As it relates to the scope and operation of the VSD...