German software company SAP SE has self-disclosed violating United States sanction laws on exporting products and services to Iran. The company admitted to carrying out thousands of export violations spanning a seven-year period. The company has agreed to pay penalties of more than $8 million as part of a global resolution reached with the US Departments of Justice, Commerce, and Treasury. It is unclear what motivated the self-reporting of SAP SE’s transgression, however, the move was praised by the US Department of Justice.
From January 2010 to September 2017, SAP and its overseas partners allegedly released US-origin software more than 20,000 times to users located in Iran. The software was exported by the German software company without a license and often included upgrades and patches. According to a statement released by the DOJ, certain SAP executives were aware of the violations and the fact that the company was not utilizing geolocation filters to identify and block Iranian downloads. Most of the downloads went to 14 companies known to be under Iranian control. The remaining downloads were sold to multinational companies that then delivered the software to their Iranian-based operations.