SAP SE — $2,132,174 OFAC penalty
OFAC published a $2,132,174 civil penalty against SAP SE on 04/29/2021. It is the #76 largest action in OFAC’s 1,052-entry enforcement chart and #3 of the 18 actions published that year.
The record
| Entity, as published by OFAC | SAP SE |
|---|---|
| Penalty / settlement amount | $2,132,174 |
| Date published by OFAC | 04/29/2021 (OFAC entry a) |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #76 of 1,052 |
| Rank within 2021 | #3 of 18 |
| Share of 2021 penalty total | 10.2% |
| Apparent violations cited | 190 |
| Statutory maximum penalty | $56,025,470 |
| Base penalty | $1,316,157 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Iran |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $56,025,470. The settled amount of $2,132,174 is 3.8% of that maximum, which OFAC's Enforcement Guidelines tie to factors including voluntary self-disclosure and whether the conduct was egregious.
Primary source
OFAC enforcement release: 20210429_sap.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2021 actions
- Bank of China (UK) Limited — $2,329,991
- Cameron International Corporation — $1,423,766
- Payoneer Inc. — $1,385,901.40
- PT Bukit Muria Jaya — $1,016,000
- Nordgas, S.r.l. — $950,000
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