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 | Enforcement Action Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Enforcement Action Dataset

 
In the Matter of Oracle Corporation · Oracle's Involvement in Multiple Countries between 2014 and 2019

Case Information

In the Matter of Oracle Corporation

Related FCPA Matter:   Oracle's Involvement in Multiple Countries between 2014 and 2019 Information

Case Information

Initiation Date:    09/27/2022  Information

Prosecuting Agency:    U.S. Securities and Exchange Commission

Type of Action:    SEC Administrative Proceeding

Docket or Case Number:    3-21158

Name of Prosecuting Attorneys:   

  • Samantha Martin, SEC Fort Worth Regional Office
  • Laura Bennett, SEC Fort Worth Regional Office
  • David B. Reece, SEC Fort Worth Regional Office

US Assisting Agencies:    Unknown

Foreign Enforcement Action/Investigation:    Unknown

Foreign Assistance:   

  • United Arab Emirates Securities and Commodities Authority (AE)
  • Indian Securities and Exchange Board (IN)
  • Turkish Capital Markets Board (TR)

Origin of the Proceeding:    Unknown

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Oracle Corporation was a multinational information technology company headquartered in Austin, Texas. Oracle’s common stock was registered with the SEC and traded on the New York Stock Exchange. Oracle employed a global workforce to service its international customers that included businesses of all sizes, government agencies, and educational institutions. Oracle operated through various subsidiaries, including Oracle India Private Limited (“Oracle India”), Oracle Bilgisayer Sistemleri Limited Sirketi (“Oracle Turkey”), and Oracle Systems Limited (“Oracle UAE”). Oracle

According to the documents in this case, between 2014 and 2019, employees of Oracle India, Oracle Turkey, and Oracle UAE used discount schemes and sham marketing reimbursement payments to finance slush funds held at Oracle’s channel partners in those markets. The slush funds were then used both to pay direct bribes to foreign officials and to provide other benefits such as paying for foreign officials to attend technology conferences around the world in violation of Oracle’s internal policies.

In a settled administrative proceeding announced on September 27, 2022, the SEC ordered Oracle to cease and desist violations of the antibribery, books and records, and internal controls provisions of the FCPA. Under the terms of the settlement, Oracle agreed to pay disgorgement of $7,114,376.44 plus prejudgment interest of $791,040.20 and a civil money penalty of $15,000,000. The SEC noted Oracle's cooperation and remediation.

Oracle was subject to a prior enforcement action by the SEC in 2012. In that proceeding, Oracle agreed to pay a $2 million penalty for violations of the books and records and internal controls provisions of the FCPA by failing to prevent Oracle India from keeping unauthorized side funds at distributors from 2005 to 2007.

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