Oracle Books & Records

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FCPA Books and Records and Internal Controls Enforcement – A Retrospective (Part III of IV)

Plan for the future because that’s where you are going to spend the rest of your life. – Mark Twain. The SEC enforces its books and records and internal controls provisions, most of which involve non-FCPA violations....more

Stretching The FCPA: The Danger Of The Oracle Case

My good friend and mentor, Judge Sporkin, is not shy nor bashful about his views on the FCPA. When he heard about DOJ’s undercover sting in the Shot Show case, he scoffed, “What a mistake! ...more

Distributors Should Be Analyzed As Any Other Third Party Representative in the Sales Chain

Ed. Note-David Simon is a partner at Foley and Lardner and Bill Athanas is a partner at Waller Lansden Dortch & Davis, LLP. Both have practices which include FCPA compliance. After my recent post on distributors under the...more

Distributors under the FCPA

If there was ever a question that distributors were covered under the Foreign Corrupt Practices Act (FCPA), in 2012, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) made it emphatically clear that...more

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