A global financial services firm closed a major SAP audit while protecting client data confidentiality through a negotiated NDA, on-premises data review protocol, and access-controlled sampling.
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The client is a global financial services firm with retail banking, capital markets, and wealth-management operations across North America, the United Kingdom, and Singapore. The SAP estate combined a long-running ECC 6.0 platform supporting finance and procurement with a partial S/4HANA conversion underway in two divisions.
An SAP audit notification arrived in the second quarter of the fiscal year, requesting a USMM run plus engine measurements for HANA runtime, BW, and Process Orchestration. The notification also requested access to user master data, transaction logs, and configuration evidence across all production systems.
The general counsel's office flagged immediate concerns. Several SAP systems carried client-identifying data subject to regulatory confidentiality requirements in three jurisdictions. The procurement and SAM teams had no protocol for handling an audit under those constraints. Outside counsel was retained before any data was exchanged.
SAP's initial scope was broad. The request for user master and transaction-log access would have exposed roughly forty-one terabytes of data including client identifiers, beneficial-ownership records, and trade history. The audit notification was framed as a routine compliance exercise; the data request was not narrowed to the licence-relevant subset.
Once measurement output was generated, SAP issued an opening position of nine point two million dollars in licence non-compliance. The claim combined a USMM under-classification, an engine measurement overage on HANA runtime, and an indirect-use exposure related to a custom client-portal integration.
Resolution was informally linked to a RISE conversion conversation, with credits available against a multi-year commitment.
Before any data was released, we negotiated a bilateral NDA covering all material exchanged, with named-individual access controls on the SAP side. The data-handling protocol prohibited removal of source data from the client environment; SAP's review took place on-premises in a controlled environment with audit-trail logging.
We refused the broad-scope data request. The licence-relevant evidence was sampled across business units according to a statistically defensible methodology; the sample excluded all client-identifying fields. The methodology was documented and agreed in writing before the sample was generated.
The internal USMM had over-classified approximately two thousand four hundred users into the Professional band. Re-classification against the sampled transaction evidence corrected the band assignment, reducing the headline user-overage figure by approximately seventy per cent.
The HANA measurement had included memory consumption attributable to a sandbox environment outside the production scope. We reconstructed the measurement excluding non-production memory; the corrected runtime usage was within the contracted band.
The custom client-portal integration had genuine indirect-use exposure, but the access pattern was read-only and the user population was a defined subset of relationship managers. We modelled the exposure under Digital Access conversion and negotiated a document-tier pricing structure with a measurement cap.
Settlement closed at two point nine million dollars in cash and conversion credits, against an opening claim of nine point two million. The reduction was approximately sixty-eight per cent. No client-identifying data was removed from the client environment at any point during the audit. The data-handling protocol was preserved through the close of the matter.
Three contract clauses were rewritten as part of the settlement: the data-access clause for future audits was narrowed to a sample-based methodology with a written confidentiality protocol; the engine measurement clause for HANA runtime was redefined to exclude non-production memory; and a settlement-as-release clause closed the audited period.
Total elapsed time from notification to signed settlement was twenty-two weeks. The longer duration reflected the data-handling protocol; the substantive defence work was completed within fourteen weeks of engagement.
The data request was the audit. Once we settled the protocol, the measurement defence became straightforward.
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