Global Arbitration, Trade and Advocacy / White Collar: Government Litigation and Investigations Update

U.S. Department of Justice Resolves First Action Under Export Control and Sanctions Enforcement Policy – Top Five Lessons Learned

May 6, 2021

In late April 2021, the German software company SAP SE (SAP) entered into nonprosecution and settlement agreements with the U.S. Department of Justice (DOJ) National Security Division, the U.S. Department of Commerce Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC). These resolutions followed SAP’s voluntary self-disclosure of violations of U.S. export control and sanctions laws and mark the first application of DOJ’s December 2019 Export Control and Sanctions Enforcement Policy, which emphasizes the importance of voluntary self-disclosure.

Please click here to read the full Sidley Update.

Attorney Advertising—Sidley Austin LLP is a global law firm. Our addresses and contact information can be found at www.sidley.com/en/locations/offices.

Sidley provides this information as a service to clients and other friends for educational purposes only. It should not be construed or relied on as legal advice or to create a lawyer-client relationship. Readers should not act upon this information without seeking advice from professional advisers. Sidley and Sidley Austin refer to Sidley Austin LLP and affiliated partnerships as explained at www.sidley.com/disclaimer.

© Sidley Austin LLP

Contacts

Special thanks to Associate Lindsey A. Ricchi for her assistance with this Sidley Update. If you have any questions regarding this Sidley Update, please contact the Sidley lawyer with whom you usually work, or