SAP SE, Exporting Software to Iran, Massachusetts 2023
BOSTON, Massachusetts - SAP SE, a global software company headquartered in Waldorf, Germany, has admitted to exporting thousands of its software products to Iran without a license and agreed to pay combined penalties of more than $8 million.
The violations occurred between January 2010 and September 2017, during which SAP released its U.S-origin software, including upgrades, and/or software patches more than 20,000 times to users located in Iran. The company's senior management was aware that neither SAP nor its U.S.-based Content Delivery Provider used geolocation filters to identify and block Iranian downloads, yet for years the company did nothing to remedy the issue.
In addition, from approximately 2011 to 2017, SAP's Cloud Business Group companies permitted approximately 2,360 Iranian users to access U.S.-based cloud services from Iran. SAP acquired these companies and became aware of their inadequate export control and sanctions compliance processes, but failed to fully integrate them into SAP's more robust export controls and sanctions compliance program.
The U.S. Attorney's Office for the District of Massachusetts and the DOJ's National Security Division entered into a Non-Prosecution Agreement with SAP due to the company's voluntary self-disclosure, extensive cooperation, and remediation costing more than $27 million. SAP will disgorge $5.14 million of ill-gotten gain and implement significant changes to its export compliance and sanctions program.
The penalties include a disgorgement of $5.14 million and a combined penalty of more than $8 million. SAP has agreed to pay this amount as part of a global resolution with the Departments of Justice, Commerce, and the Treasury.
The Non-Prosecution Agreement recognizes the importance of voluntary self-disclosure and cooperation with the government. SAP's actions constitute serious violations of U.S. law involving the release of U.S. origin technology and software through cloud servers and online portals.
SAP SE is a global software company headquartered in Waldorf, Germany. The company has admitted to exporting software to Iran without a license and agreed to pay $8 million in penalties. The violations occurred between January 2010 and September 2017.
Defendant: SAP SE
Criminal Charges: Exporting software to Iran without a license
City and State: Boston, Massachusetts
Date: Ongoing from January 2010 to September 2017
Sentence: SAP SE agreed to pay $8 million in penalties, disgorging $5.14 million of ill-gotten gain, and implementing significant changes to its export compliance and sanctions program.
Key Facts
- State: Massachusetts
- Category: Cybercrime
- Source: DOJ Press Release â†â€â€
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