So, SAP got slapped on the wrist with a $2.1 million dollar fine for some pretty reckless behavior. And it was larger than the $1.3 million base penalty - but OFAC called the violations non-egregious. Huh?

Turns out that OFAC defines what makes a violation egregious - so, let’s look at it, and compare what SAP did to, say, Nordgas S.r.l. did. Here’s a hint: Nordgas’ violations were considered egregious.

As always, I have thoughts on all this…