German software company SAP SE recently entered into a three-year deferred prosecution agreement with the DOJ. The case is the DOJ’s second coordinated resolution with South African authorities in just over a year. It is also the second time that SAP has been recognized for its cooperation and remediation, which, according to Acting Assistant AG Nicole M. Argentieri, was incentivized by the DOJ’s coordinated international efforts and its corporate enforcement policies. This article examines the SAP case and offers insight into where regulators are looking next to incentivize companies to be good citizens, with insights from Withersworldwide, Miller & Chevalier, Davis Polk and Compliance Systems Legal Group. See “Gartner’s Settlement for FCPA Violations in South Africa Raises Important Issues” (Jun. 21, 2023).