Geopolitical Impact on Enterprise Systems: Qui a le droit? Strengthening SAP Security & Controls in Uncertain Times (3/3)

Now that we've completed Parts 2 and 3, let's wrap up this series.

7. Enforcing Controls in Non-Production SAP Systems

Geopolitical tensions and regulatory fragmentation significantly impact how organizations secure non-production SAP environments. Non-production SAP systems, such as development, test, or sandbox environments, often contain replicated production data, making them a critical but frequently overlooked compliance risk. To remain compliant with regulations like the GDPR and the Digital Operational Resilience Act (DORA), companies must enforce both technology-based controls (e.g., data masking, scrambling, or anonymization) and process-based controls (e.g., logging and monitoring of user access). Non-production systems with unprotected data may violate data sovereignty laws.

Access controls must be rigorously enforced to protect sensitive or personal data from unauthorized exposure or processing outside of regulatory requirements. Particular care should be taken to prevent any changes originating from non-production environments (such as development or testing) from affecting production systems, or to ensure that data is not extracted from production and misused in lower environments. All interactions between environments should be thoroughly logged, with any deviations from standard behavior immediately triggering alerts. These measures are essential for mitigating the risks of insider threats, data breaches, and non-compliance

8. Managing Internal Fraud and Segregation of Duties

Geopolitical tensions increase the risk of internal fraud, especially when employees in sanctioned regions still have SAP access. Common schemes involve manipulating invoices using transactions like MRBR or FB02, but the risks extend further. Unusual changes to payment terms (FBZP), vendor master data (FK0)/FK02). Sanctions can be bypassed by rerouting payments via neutral countries)

EU’s DORA and U.S. SEC Rules demand proof of SoD enforcement, especially for firms operating in conflict zones. Effective mitigation starts with enforcing Segregation of Duties across both human and machine identities. High-risk activities—such as vendor creation, tariff code changes, purchasing, and releasing blocked invoices or payments—should never be concentrated under a single user or bot.

Machine identities, like background jobs or integration users (e.g., in PI/PO or middleware), can sometimes bypass human controls if not properly governed. These identities must have restricted and monitored access, especially when they touch critical processes or sensitive data.

Even changes to tariff codes (FTXP) or material master data (MM01/MM02)—which influence sales orders, inventory, and goods receipts—require close oversight. If left unchecked, small manipulations here can snowball into major financial discrepancies or compliance violations.

Conclusion: A Call to Action

The geopolitical landscape continues to evolve rapidly, and businesses must take immediate action to safeguard their SAP systems from emerging threats and compliance challenges. To ensure continued success in an uncertain and turbulent environment, organizations should focus on the following short-term and medium-term goals:

Short-Term Goals (0-6 months):

1. Conduct a Geopolitical Risk Assessment for SAP: Quickly assess your SAP systems to identify vulnerabilities in both your technological framework and compliance processes.
2. Implement Automated Sanctions and Trade Compliance Screening: Integrate automated tools into SAP processes to ensure that restricted entities are flagged in real time, reducing the risk of sanctions violations.
3. Enhance Cybersecurity Defenses: Immediately strengthen access controls and begin implementing real-time monitoring systems to identify and mitigate potential security breaches.
4. Institute Stricter Access Controls: Begin enforcing stricter access protocols to sensitive systems and data, limiting changes to authorized personnel only.
5. Review and Implement Regional Data Privacy Measures: Ensure sensitive data complies with regional data privacy regulations, keeping it within the appropriate jurisdictions.

Medium-Term Goals (6-18 months):

1. Ongoing Cybersecurity Enhancements: Expand your security measures with advanced features such as multi-factor authentication (MFA) and encryption for critical data.
2. Segregate High-Risk Regional Systems: Isolate or segment systems in politically unstable regions to minimize the impact of local geopolitical disruptions.
3. Refine and Update Master Data Controls: Regularly review and update master data, especially for critical elements such as tariff codes, country-of-origin data, and sanctioned vendors, to ensure compliance with ever-changing regulations.
4. Establish Continuous Compliance Monitoring: Develop a continuous monitoring framework for SAP systems, integrating compliance checks and alerts that are updated in real-time to reflect evolving geopolitical situations.
5. Strengthen Data Privacy Compliance Measures: Implement advanced encryption techniques and data masking for highly sensitive information, ensuring full compliance with national and regional regulations over time.

By addressing these critical areas proactively, businesses can mitigate the risks posed by the complex and unpredictable geopolitical environment, safeguarding their SAP systems, ensuring compliance, and protecting their global operations from disruption.

I hope you have found this article valuable.