Barbara Linney: Tech in sights of regulators? The SAP settlement and its meanings

In April 2021, Germany’s SAP agreed combined penalties of $8m with the US Department of Justice, Bureau of Industry and Security and Department of the Treasury for exports of software products and services to Iran.

The sum wasn’t eye-watering, but the settlement was hugely instructive not only because it underscored regulators’ increasing focus on technology companies and intangible technology, and also on account of its multi-agency nature – and the role of the Department of Justice.

In her presentation, Barbara Linney takes a close look at the SAP settlements, exploring lessons that should be learnt by the tech industry and beyond, whether US or non-US based, including companies engaged in M&A activities.

About Barbara: Barbara Linney serves as BakerHostetler’s International Trade & National Security team co-leader, building on 30 years of experience advising US and foreign clients. She is also an adjunct professor of export controls and economic sanctions at Georgetown University Law Center – and winner of the WorldECR Practitioner of the Year Award, 2021.