WASHINGTON – On April 29 2021, Kevin J. Kurland, Acting Assistant Secretary for Export
Enforcement, Bureau of Industry and Security (BIS) of the U.S. Department of Commerce,
announced an administrative settlement of $3,290,000 with SAP SE (SAP), a multinational
software company based in Walldorf, Germany. SAP also agreed to complete three audits of its
export compliance program over a three year period. SAP voluntarily self-disclosed potential
violations of the Export Administration Regulations (EAR) to BIS, and cooperated with the
investigation conducted by the Boston Field Office of BIS’s Office of Export Enforcement.

“The Bureau of Industry and Security strongly encourages companies, including software
providers, to maintain robust export compliance programs to prevent violations of the EAR,”
said Mr. Kurland. “If violations do occur, submitting a voluntary self-disclosure of the
violations to BIS will be a significant mitigating factor in any penalties imposed.”

This settlement resolves BIS’s allegations that, during a period including December 2009
through September 2019, SAP engaged in conduct prohibited by the EAR when it exported SAP
products including software, upgrades, and patches from the United States to various end users
located in sanctioned countries, including Iran, without the required export licenses. The items
were controlled for encryption and national security reasons. The U.S. Department of Justice
and Office of Foreign Assets Control of the U.S. Department of the Treasury also entered into
agreed-upon resolutions with SAP involving related conduct of concern.

BIS’s mission is to advance U.S. national security and foreign policy objectives by ensuring an
effective export control and treaty compliance system and promoting continued U.S. strategic
technology leadership. Among its enforcement efforts, BIS is committed to preventing U.S.-
origin items from supporting Weapons of Mass Destruction projects, terrorist activities, or
destabilizing military modernization programs.

For more information, please visit www.bis.doc.gov.