The amount to be paid, however, is being cut substantially by credits for payments to South Africa. SAP was given credit for immediately cooperating with South African authorities when accusations were first made in 2017. However, the SEC said SAP’s controls “did not address high risk of bribery in those countries” and failed to implement payment approval controls to make sure services were actually rendered  or expenses occurred and lacked entity-level controls. The South Africa offenses occurred from about 2013 through 2017 and from about 2015 and 2018 in Indonesia. The SEC and SAP agreed to $85 million in disgorgement and $13.4 million of prejudgment interest, but this is being offset by $59.5 million paid to South African authorities, resulting in a total required payment of $39 million. The Justice Department Assessed a criminal penalty of $111.8 million and an administrative forfeiture of $103 million. That will be credited up to $55.1 million for any amounts paid to South Africa in its investigation.