Oracle Enforcement Action Again “Diluted”

A decade ago, Mike Koehler wrote about a corruption case against Oracle Corporation, with the headline “The Dilution Of FCPA Enforcement Has Reached A New Level With The SEC’s Enforcement Action Against Oracle.” With Oracle again in the SEC's crosshairs, Koehler writes that the recent action against it is again “diluted.” He argues that Oracle—which had all the requisite policies and procedures in place within its own organization—is being blamed for actions at value-added distributors and value-added resellers.