An SEC investigation found that the man a former vice president of global and strategic accounts for a software company, orchestrated a scheme to pay $145,000 in bribes to one government official and promised to pay two others in order to obtain four contracts to sell the company's software to the Panamanian government. He essentially caused the software company, which is headquartered in Germany and executes most of its sales through a network of worldwide corporate partners, to sell software to a partner in Panama at discounts of up to 82 percent. The excessive discounts enabled the partner to create a slush fund from its excessive earnings on the other end of the sales and tap that money to pay the bribes to Panamanian government officials so SAP could sell the software. The man, who lives in Miami, also received kickbacks from the slush fund into his bank account.
To read the entire SEC Press Release please follow this link: FCPA Charges for Software Executive