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U.S. Department of Justice
National Security Division
Counterintelligence and Export Control Section
Washington, D.C. 20530
April 20, 2021
Kwame J. Manley, Esq.
Robert Luskin, Esq.
Paul Hastings LLP
2050 M Street, NW
Washington, DC 20036
Dear Attorneys Munley and Luskin,
The United States Department of Justice's National Security Division and the United States Attorney's Office for the District of Massachusetts (collectively, "the Offices"), and SAP SE ("SAP" or the "Company"), enter into this Non-Prosecution Agreement (the "Agreement"). The Offices, based on the understandings specified below, will not criminally prosecute the Company for any crimes relating to the conduct described in the Statement of Facts attached hereto as Attachment A (the "Statement of Facts"). The Company, pursuant to authority granted by the Company's Board of Directors, also agrees...
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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...