This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) approximately...more
When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts. Some would argue that DOJ has been consistent all along. The truth, like most issues, lies somewhere between the extremes....more
Life is always filled with surprises. Just when we thought 2023 was a “slow” FCPA enforcement year, DOJ and SEC announced a large enforcement action against SAP for approximately $220 million for FCPA violations in South...more
DOJ and SEC Announce Settlement with PTC, Inc. in FCPA Case Involving SEC’s First Individual Deferred Prosecution Agreement - On February 16, 2016, the U.S. Securities and Exchange Commission (SEC) and the U.S....more
A CD or not a CD, That is the Question… That the Auditors Should Have Answered - A headline-grabbing SEC enforcement action last week against BDO USA and several of its national partners may lead audit firms to insist on...more
One of the most difficult stories of the Bible for me was always that of God and Abraham. But somehow this song explained it for me as it deals with some unusual problems that can be solved out on Highway 61, which is a...more