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Securities
Securities Fraud
Foreign Corrupt Practices Act

U.S. Securities and Exchange Commission v. Oracle Corporation

Published: Sep. 29, 2012 | Result Date: Aug. 27, 2012 | Filing Date: Jan. 1, 1900 |

Case number: 3:2012-cv-04310 CRB Settlement –  $2,000,000

Court

USDC Northern


Attorneys

Plaintiff

Elena Ro

Marc J. Fagel

Michael S. Dicke
(Fenwick & West LLP)

Jina L. Choi
(Morrison & Foerster)


Defendant

Leslie R. Caldwell


Facts

The Securities and Exchange Commission (SEC) sued Oracle Corp. (Oracle), alleging that Oracle violated the books and records and internal controls provisions of the Foreign Corrupt Practices Act and created the potential within its organization for bribery when its employees created a secret side fund and then diverted money from the fund to various strawman vendors.

Result

Oracle will pay a $2,000,000 civil penalty to the SEC and has implemented internal measures to prevent the formation of another secret fund.


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