SAP Bribery Case Shows US Mercy to Cooperating Recidivist (1)

The Justice Department’s $220 million settlement with software multinational SAP SE for bribing foreign officials signals that even repeat-offending companies can benefit from meaningful cooperation.

US prosecutors emphasized the appeal of several incentives featured in the Biden administration’s newly-revised corporate enforcement policies while entering into a deferred prosecution agreement with the German software company Wednesday for conspiring to violate the Foreign Corrupt Practices Act. The settlement comes less than three years after its non-prosecution pact for violating Iranian sanctions.

In the new settlement, SAP received a 40% penalty discount, avoided an independent compliance monitor, and will escape indictment if it ...