SEC order against recidivist Oracle skirts the issue


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.

Companies and regulators alike are intentionally tactical about the details they craft publicly in settlement agreements. For the compliance profession to glean anything truly insightful requires reading between the lines.

In September, Oracle, without admitting or denying SEC’s findings, agreed to pay more than $23 million to resolve charges of FCPA violations resulting from sales employees at the technology company’s Turkey, United Arab Emirates (UAE), and India subsidiaries allegedly engaging in multiple schemes whereby they created and used slush funds to bribe foreign officials over several years.

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