German software developer SAP SE, product reseller Carahsoft Technology Corp. and other companies are being probed by U.S. officials for potentially conspiring to overcharge government agencies over the course of a decade.
Since at least 2022, Justice Department lawyers have been looking at whether SAP — which makes accounting, human resources, supply chain and other business software used across the globe — illegally conspired with Carahsoft to fix prices on sales to the U.S. military and other parts of the government, according to federal court records filed in Baltimore.
The civil investigation, which hasn’t previously been reported, poses a legal risk to a top technology vendor to the U.S. government and to Germany’s most valuable company as its shares are soaring.
The review also shines an even greater light on Carahsoft, a large software vendor whose offices in Virginia were raided on Tuesday by FBI agents and military investigators.
Carahsoft spokesperson Mary Lange described the search as “an investigation into a company with which Carahsoft has done business in the past.” It’s not clear if the search is related to the investigation of SAP. Lange and other Carahsoft representatives declined to answer detailed questions.
A logo on an office at the SAP SE campus in Walldorf, Germany.
Alex Kraus/Bloomberg
SAP has been cooperating with the DOJ’s civil investigation “since the beginning,” spokesman Daniel Reinhardt said in an emailed statement. The German company is not involved in any criminal investigation related to Carahsoft and has no information about “the latest events” concerning its vendor, he said.
SAP shares dropped 2.4% to close at €201.80 in Frankfurt on Wednesday. The shares have risen about 44% this year.
News of the probe also had knock-on effects for shares of ServiceNow Inc. and Okta Inc., which both “saw over 40% of disclosed federal contract dollars come through Carahsoft,” according to a note from Piper Sandler. Shares of ServiceNow fell as much as 4% on Wednesday. Okta shares declined as much as 1.7%.
Civil probe
The long-running civil probe is focused on the companies possibly rigging the market for the more than $2 billion worth of SAP technology that the U.S. government has purchased since 2014, according to the court records. They show prosecutors are also examining the role of other software resellers and a unit of Accenture, a giant management and technology consulting firm.
Many investigations end without any formal accusations of wrongdoing.
Accenture spokesperson Peter Soh said the subsidiary, Accenture Federal Services LLC, “is responding to an administrative subpoena and is cooperating with the DOJ.” The Justice Department didn’t respond to requests for comment.
The Justice Department classifies bid rigging as a form of fraud that involves an agreement among competitors as to who will be the winning bidder.
The investigation came to public light in an ongoing court fight between the prosecutors and Carahsoft over the closely held firm’s handling of a legal demand for documents. While many records in that separate proceeding are sealed or heavily redacted, unredacted versions of documents describing the underlying investigation were also publicly available.
False Claims Act
It’s unclear exactly when prosecutors began examining the relationship between SAP, which has its headquarters in Walldorf, Germany, and Carahsoft, based in Reston, Virginia. But by June 2022 prosecutors had sent Carahsoft a demand to turn over documents and provide information related to potential violations of the False Claims Act.
The civil investigative demand — which was among the unredacted documents obtained by Bloomberg News — states that prosecutors are examining whether SAP, Carahsoft and other firms made false statements to the Department of Defense by coordinating bids and prices for “SAP software, cloud storage, and related hardware and services.” The document directs Carahsoft to produce a wide array of emails, text messages, contracts, staff lists and other information related to its sale of SAP software.
More than a year later, federal prosecutors sued Carahsoft, seeking to have a federal judge in Baltimore enforce the demand and alleging that the company has “obstinately refused to provide this basic information.” Back-and-forth litigation in the case — much of it sealed from public view — continued up to last Friday, when it was assigned to a new magistrate judge for pretrial fact-finding known as discovery.
One of Carahsoft’s lawyers, Richard Conway, declined to answer questions about the case, the civil investigation or the FBI search of his client’s office.
“I don’t discuss such matters in the press,” he said when reached by phone Tuesday.
In response to questions about the FBI search, Lange said Carahsoft is “fully cooperating on this matter” and “operating business as usual.”
Carahsoft dominant
Since its founding in 2004, Carahsoft has grown into a dominant player in the government technology procurement market. Last year, it ranked 45th on Forbes’ list of the largest private companies in the U.S., with $11 billion in estimated revenue and more than 2,400 employees.
Among all federal vendors of IT products, Carahsoft holds the second-highest value of contracts directly with the government, totaling $3.5 billion since the beginning of fiscal 2020, according to Bloomberg Government data. Only Dell Technologies Inc. has more revenue.
SAP technology is a big chunk of this business. Carahsoft received more than 600 federal contracts for SAP tech worth more than $990 million and “facilitated” as much as $1 billion more in additional sales, prosecutors said in court filings.
It’s unclear what portion of these sales prosecutors believe might have been shaped by bid rigging. The False Claims Act allows the government to recover up to three times its damages plus a penalty.
Both SAP and Carahsoft have had other run-ins with the Justice Department.
In 2015, Carahsoft and VMware LLC agreed to pay $75.5 million to resolve allegations in a False Claims Act lawsuit accusing them of overcharging the government for VMware’s software and services from 2007 to 2013, according to a statement from the department.
Deferred prosecution
In January, SAP agreed to pay more than $220 million to resolve a foreign bribery investigation by U.S. authorities. The company entered into a three-year, deferred-prosecution agreement with the Justice Department after it was charged in a pair of schemes to bribe government officials in South Africa and Indonesia.
Earlier this month, German prosecutors opened a criminal probe into the company’s chief technology officer, who is stepping down due to “inappropriate” behavior.
The new investigation comes to light as SAP’s share price has been hitting record highs amid a corporate restructuring. This year, chief executive officer Christian Klein has cut jobs and spending at the company, even as other executives have left or announced their departures in recent months.
The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.
The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.
Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.
Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.
Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.
Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.
Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.
Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.
Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.
In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.
Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.
Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.
Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.
Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.
Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.
The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.
In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.
AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.
When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.
Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.
This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.
Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.