On August 16, 2012, the SEC filed a complaint against Oracle Corporation. According to the SEC: "This matter involves violations of the books and records and internal controls provisions of the Foreign Corrupt Practices Act ('FCPA') by Oracle Corporation.... From 2005 to 2007, certain employees of Oracle's Indian subsidiary Oracle India Private Limited ('Oracle India') secretly 'parked' a portion of the proceeds from certain sales to the Indian government and put the money to unauthorized use, creating the potential for bribery or embezzlement. These Oracle India employees structured more than a dozen transactions so that a total of around $2.2 million was held by the Company's distributors and kept off Oracle India's corporate books. The Oracle India employees would then direct its distributor to disburse payments out of the unauthorized side funds to purported local 'vendors.' Several of the 'vendors' were merely storefronts that did not provide any services."

On August 16, 2012, the SEC announced that it charged Oracle Corporation ("Oracle") with violating the Foreign Corrupt Practices Act ("FCPA") by failing to prevent a subsidiary from secretly setting aside money off the company's books that was eventually used to make unauthorized payments to phony vendors in India. According to the SEC's complaint filed in U.S. District Court for the Northern District of California, the misconduct at Oracle's India subsidiary--Oracle India Private Limited ("Oracle India")--occurred from 2005 to 2007. Oracle India sold software licenses and services to India's government through local distributors, and then had the distributors "park" excess funds from the sales outside Oracle India's books and records. Without admitting or denying the SEC's allegations, Oracle consented to the entry of a final judgment ordering the company to pay a $2 million penalty and permanently enjoining it from future FCPA violations. The settlement takes into account Oracle's voluntary disclosure of the conduct in India and its cooperation with the SEC's investigation, as well as remedial measures taken by the company, including firing the employees involved in the misconduct and making significant enhancements to its FCPA compliance program.

On August 27, 2012, Federal District Judge Charles R. Breyer entered final judgment against Oracle Corporation pursuant to the consent of Oracle Corporation.