Tagged: sham marketing reimbursement

Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II)

Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of conduct beyond foreign bribery.  The SEC recognizes the power of these provisions and have used them in a variety of settings. Oracle has now fallen under the enforcement sword twice —...