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Turkey

Turkey

I hope this Thanksgiving finds you being thankful for many things in your life.

Among the many things I am thankful for are your readership and I hope FCPA Professor elevates your FCPA knowledge and skills.

May your turkey be golden brown.

The following FCPA enforcement actions have involved, in whole or in part, alleged improper conduct in Turkey.

Continue Reading

Turkey

Turkey

I hope this Thanksgiving finds you being thankful for many things in your life.

Among the many things I am thankful for are your readership and I hope FCPA Professor elevates your FCPA knowledge and skills.

May your turkey be golden brown.

The following FCPA enforcement actions have involved, in whole or in part, alleged improper conduct in Turkey.

Continue Reading

Oracle Becomes The 20th Corporate FCPA Repeat Offender

oracle

As highlighted in this prior post, in 2012 Oracle resolved a $2 million SEC Foreign Corrupt Practices Act enforcement action finding that “Oracle violated the books and records and internal accounting controls provisions of the FCPA by failing to prevent Oracle India Private Limited from keeping unauthorized side funds at distributors from 2005 to 2007.”

As a condition of settlement,¬†Oracle consented to the entry of a final judgment, among other things, “permanently enjoining it from future violations” of the books and records and internal controls provisions and in resolving the matter the SEC noted the “significant enhancements” Oracle made to its FCPA compliance program.

Yesterday, the SEC announced a $22.9 million FCPA enforcement action against Oracle “to resolve charges that it violated provisions of the FCPA when subsidiaries in Turkey, the United Arab Emirates, and India created and used slush funds to bribe foreign officials in return for business between 2016 and 2019.”

In resolving a second FCPA enforcement action, Oracle becomes the 20th corporate FCPA repeat offender (see here for the list).

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Turkey

Turkey

I hope this Thanksgiving finds you being thankful for many things in your life.

Among the many things I am thankful for are your readership and I hope FCPA Professor elevates your FCPA knowledge and skills.

May your turkey be golden brown.

The following FCPA enforcement actions have involved, in whole or in part, alleged improper conduct in Turkey.

Continue Reading

Turkey

Turkey

I hope this Thanksgiving finds you being thankful for many things in your life.

Among the many things I am thankful for are your readership and I hope FCPA Professor elevates your FCPA knowledge and skills.

May your turkey be golden brown.

The following FCPA enforcement actions have involved, in whole or in part, alleged improper conduct in Turkey.

Continue Reading

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