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The SAP and Garcia FCPA Enforcement Actions - The Government Speaks, Are You Listening?

Tom Fox | February 9, 2016

You cannot say the government does not communicate its expectations around Foreign Corrupt Practices Act enforcement. The SEC concluded its investigation around the illegal activity engaged in by former SAP International Vice President of Global and Strategic Accounts, Vicente Garcia, for bribery and corruption in sales to certain government officials in Panama; all in violation of the FCPA. This enforcement action presents some clear signs about where FCPA enforcement will be headed into 2016 and beyond.

In December 2015 Garcia was sentenced to 22 months in prison for bribing officials in Panama to win government...

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