Lessons for compliance practitioners in the tech sector – Garcia FCPA enforcement action

Last month, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) jointly announced an enforcement action for violations of the Foreign Corrupt Practices Act (FCPA) against a former executive of the SAP International Inc. for bribery and corruption to procure government contracts in Panama. Even at this point, with no DOJ or SEC action against SAP, there are several lessons for compliance practitioners.