Five Important Lessons for Compliance Officers from the Oracle FCPA Settlement

Oh, recidivists.

If you’ve already been fined for bribery, don’t do it again! Alas, for Oracle, history has repeated itself with a second series of FCPA violations. The facts, as laid out in the SEC Order, are pretty fascinating.

But more important are the lessons that can be learned to ensure our programs better prevent and detect bribery and misconduct.