On Aug. 12, 2015, Vincente Garcia (former head of Latin American sales for SAP International Inc.) pled guilty in federal court in San Francisco to violations of the Foreign Corrupt Practices Act. In addition to pleading guilty to a criminal information filed by the U.S. Department of Justice, Garcia also settled civil FCPA charges brought by the U.S. Securities and Exchange Commission in a rare simultaneous FCPA enforcement action against an individual. SAP International was a wholly owned U.S. subsidiary of global technology services company SAP SE, which is based in Germany.

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In mid-July, the DOJ quietly filed a one-count criminal information against Garcia in the Northern District of California, charging him with conspiracy to violate the FCPA’s anti-bribery provisions, 15 U.S.C. § 78dd-2, as Garcia is a U.S. citizen and thus a “domestic concern.” On Aug. 12, Garcia pled guilty. According to the charges, Garcia participated in a scheme to bribe Panamanian officials to secure government technology contracts for SAP from 2009 to 2013.

Originally published in Law360, New York on August 26, 2015.