No Oracle Could Have Foreseen Oracle's FCPA Settlement

Law360, New York (September 5, 2012, 12:08 PM EDT) -- On Aug. 16, the U.S. Securities and Exchange Commission announced a settlement with Oracle Corporation in which the California software company agreed to pay a $2 million penalty to settle charges that it violated the books and records and internal controls provisions of the U.S. Foreign Corrupt Practices Act.[1] Notably absent from the enforcement action was any allegation of an improper payment to a foreign government official — an element present in practically all other FCPA enforcement actions to date.

This enforcement action is significant because...
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