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Oracle – Another World’s Most Ethical FCPA Violator?

It surprises most people to learn that a company with pre-existing FCPA compliance policies and procedures – and a company otherwise making good faith efforts to comply with the FCPA –  can still face...

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The Latest Disclosures

A Friday focus on disclosures.  The SEC asks Oracle – what about that FCPA issue, the SEC takes an interest in Libya, and yet another voluntary disclosure. Oracle As noted in this previous post, in...

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Friday Roundup

Checking in on Wal-Mart, an enforcement action that flew under the radar from beginning to end, a guilty plea in the U.K., and is sex a thing of value?  It’s all here in the Friday roundup. Wal-Mart...

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The Dilution Of FCPA Enforcement Has Reached A New Level With The SEC’s...

Yesterday,the SEC announced (here) a Foreign Corrupt Practices Act books and records and internal controls enforcement action against Oracle Corporation. With the enforcement action, the dilution of...

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Scrutiny Alerts And Updates

This post revisits themes originally explored in this prior post “The Sun Rose, A Dog Barked and a Company Disclosed FCPA Scrutiny” and this prior post “Recent Disclosures Raise Many Questions.” Why,...

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Former Assistant Chief Of The DOJ’s FCPA Unit Blasts Aspects Of SEC FCPA...

This post has a similar theme to this prior post.  The theme is – all one has to do is wait for former DOJ and SEC FCPA enforcement officials to blast various aspects of the current FCPA enforcement...

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