According to the regulator, Oracle's Turkey and UAE units also used slush funds to pay for foreign officials to attend technology conferences in violation of Oracle policies. Employees of the Turkey unit also used the funds to pay for the officials' spouses and children to accompany them, or take side trips to Los Angeles and Napa Valley, California, the SEC said. "The creation of off-book slush funds inherently gives rise to the risk those funds will be used improperly, which is exactly what happened here," Charles Cain, chief of the SEC's FCPA unit, said in a statement. Oracle, based in Austin, Texas, agreed to pay a $15 million civil fine and about $7.9 million of disgorgement and interest. It did not admit or deny wrongdoing in agreeing to settle. "The conduct outlined by the SEC is contrary to our core values and clear policies, and if we identify such behavior, we will take appropriate action," Oracle spokesman Michael Egbert said.