Oracle recently reached a $23‑million FCPA settlement with the SEC, marking the second time the agency has resolved claims that Oracle had insufficient compliance controls in India. "The continued behavior here makes it look like, perhaps, Oracle didn’t do a fulsome root-cause analysis and put in place the proper controls to prevent similar misconduct from happening in the same country,” Laura Perkins, a partner at Hughes Hubbard, told the Anti-Corruption Report. We analyze the settlement and look at how the bribery scheme, which included discount and slush funds, could have been prevented. See “Doing More With Less: Tools for Managing Third-Party Risk With Scarce Resources
,” (Apr. 28, 2021).