The most notable and relevant details in settlement agreements concerning regulatory compliance violations are often what is not stated. The Securities and Exchange Commission’s (SEC) cease-and-desist order against recidivist Oracle over violations of the Foreign Corrupt Practices Act (FCPA) is no exception.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...