SAP SE Settlement With US Federal Agencies Signals Additional Sanctions and Export Controls Compliance Burden

On April 29, 2021, SAP SE (SAP), a leading international provider of enterprise application software based in Germany, entered into settlements and a non-prosecution agreement (collectively, the SAP settlements) with US federal agencies for alleged violations of US sanctions and US export controls with respect to Iran.   SAP entered into a non-prosecution agreement with the … Read more

BitPay Settlement Signals Growing OFAC Focus on Cryptocurrency Transactions

On February 18, 2021, BitPay, Inc. (“BitPay”), a major cryptocurrency payment processing platform, entered into a $507,000 settlement with the Office of Foreign Asset Control (“OFAC”), to settle allegations that it processed cryptocurrency payments which violated various US sanctions programs.  Significantly, OFAC did not allege that BitPay knowingly violated sanctions laws or took steps to … Read more