Oracle Hit 2nd Time on FCPA Violations

Oracle

The Securities and Exchange Commission has sanctioned Oracle for violations of the FCPA, the software giant’s second such incident in 10 years and one that provides a chance for the rest of us to talk about recidivist FCPA offenders.  What happened? In one sense, the usual. Throughout the 2010s, Oracle subsidiaries in India, Turkey, and…

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SEC Hits VMWare on Earnings Management

VMWare

The Securities and Exchange Commission slapped software giant VMWare with accounting fraud charges Monday, accusing it of slow-rolling the delivery of software to customers so the company could prop up its order backlog and delay revenue recognition into future quarters.  VMWare will pay $8 million to settle the charges, a paltry sum for a $10…

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Fresh Lessons on Management Fraudsters

fraud

One of the largest PR firms in the world is going through its own minor PR crisis this week, with its former CFO pleading guilty to embezzling $16 million from the firm over the course of nearly a decade.  Frank Okunak, who ran financial operations at PR firm Weber Shandwick from 2009 to 2019, pleaded…

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Why Segregation of Duties Matters

segregation

Today I want to circle back to that crazy case from Georgia, of a corporate lawyer disbarred for fabricating employee complaints so he could then draw up phony settlements and embezzle the money. The misconduct alone is astonishing, but we should also ask: what are the internal control failures that would allow something like this…

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SEC Hits Software Firm on Accounting Fraud

internal control

The Securities and Exchange Commission has fined a New Jersey software firm $12.5 million for accounting fraud in the 2010s, in a case offering multiple lessons about poor management and internal control failures in the tricky world of software sales.  The company in question is Synchronoss Technologies, which sells software to telecommunications firms. The SEC…

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FCPA Reminders From Stericycle

Stericycle, the global medical waste giant, has agreed to settle FCPA charges against the company for widespread bribery in Latin America, giving the rest of us another case with lessons about the risks of rapid international growth and poor corporate culture. The settlement was announced Wednesday. Stericycle will pay $84 million in penalties to the…

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KT Pays $6.3M to End FCPA Case

KT

Compliance professionals have quite the FCPA case to consider this week, courtesy of the Securities and Exchange Commission hitting Korea’s largest telecommunications carrier with $6.3 million in penalties and disgorgement for all manner of corrupt practices in the 2010s. The company, KT Corp., has a long history of corruption. KT agreed to settle the SEC…

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SEC’s Interesting Remediation Example

lawyers

The Securities and Exchange Commission published a press release Friday afternoon that compliance professionals should welcome: news that a tech startup mired in financial fraud will not pay any monetary penalties, thanks to the company’s extensive cooperation and remediation.  We rarely see an announcement like this, where the SEC’s principal point is to discuss its…

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Notes on Assessing Your Internal Controls

internal control

One of the Securities and Exchange Commission’s senior enforcement officials gave a pep talk in Washington this week about the importance of internal controls, and how a company should evaluate its internal controls this winter as the world tries to prevail over the disruptions of covid-19. The official was Matthew Jacques, chief accountant in the…

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That Lawsuit Against J.P.Morgan

JP Morgan

As you might have already heard (because compliance is such a gossipy profession), last week a former compliance officer for J.P.Morgan filed a lawsuit against the bank, accusing executives there of retaliating against her because she was raising concerns about failures and weaknesses in the compliance program.  I spent the weekend reading the complaint, which…

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