Corruption, Crime, and Compliance – A Deep Dive into the Oracle FCPA SEC Settlement | Thomas Fox – Compliance Evangelist


The Compliance Podcast Network welcomes the re-launching of the new Corruption, Crime, and Compliance podcast, where Michael Volkov takes a deep dive into the Oracle case and provides valuable lessons for managing third-party corruption risks. Oracle Corporation settled its second FCPA case in ten years. It agreed to pay the SEC $23 million to resolve allegations that its subsidiaries in Turkey, India, and the United Arab Emirates maintained slush funds to bribe foreign officials. Ten years ago, in 2012, Oracle paid the SEC $2 See more +

The Compliance Podcast Network welcomes the re-launching of the new Corruption, Crime, and Compliance podcast, where Michael Volkov takes a deep dive into the Oracle case and provides valuable lessons for managing third-party corruption risks. Oracle Corporation settled its second FCPA case in ten years. It agreed to pay the SEC $23 million to resolve allegations that its subsidiaries in Turkey, India, and the United Arab Emirates maintained slush funds to bribe foreign officials. Ten years ago, in 2012, Oracle paid the SEC $2 million for creating millions of dollars in off-the-books accounts at its India subsidiary.

Highlights of this podcast include:

1. In the SEC’s mind, Oracle is a recidivist, having its second enforcement action case in 10 years.

2. Michael remarks that the settlement for $23 million underscored the power of the FCPA provisions, which mandate effective internal controls and accurate books and records and can be applied to a wide range of conduct beyond foreign bribery.

3. Oracle’s controls to prevent improper use of discounts and marketing reimbursements were ineffective because the business lacked a compliance culture.

4. Compliance professionals should study the Oracle case, Michael believes. It reminds you to look at your controls surrounding discounting and ensure the documentation is carried out. “No matter what controls you have in place, they still have to be adhered to with a true culture of compliance underneath it as a foundation,” he adds.

Tune in to the Corruption, Crime, and Compliance podcast to learn more on A Deep Dive into the Oracle FCPA SEC Settlement with Michael Volkov. See less –