Oracle Settles With SEC Again

Oracle has admitted to violating the Foreign Corrupt Practices Act for the second time in 10 years. On Sept. 27 it agreed to pay the SEC $22.9 million for using slush funds to bribe foreign officials in return for business in Turkey, India, and the United Arab Emirates. In 2012, the company paid $2 million to settle FCPA charges arising from a slush fund in India. From 2009 to 2019, Oracle used excessive discounts and sham marketing reimbursement payments to create off-book slush funds in Turkey, according to the SEC. The funds were used to pay travel expenses for foreign officials’ spouses and children, including side trips to Los Angeles and Napa Valley. In the UAE from 2014 to 2019, sales employees “used both excessive discounts and marketing reimbursement payments to maintain slush funds . . . to pay for the travel and accommodation expenses of end customers, including foreign officials, to attend Oracle’s annual technology conference in violation of Oracle’s internal policies,” the SEC said. It also announced that it took into account Oracle’ s self-reporting (including self-reporting unrelated conduct) and other remedial efforts. Dorian Daley, Oracle’s legal group leader, postponed her planned retirement for a short time, apparently in connection with the settlement.