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Is Cognizant Technology “Boiling The Ocean”?

Boiling the Ocean

This prior post highlighted the Foreign Corrupt Practices Act scrutiny of Cognizant Technology Solutions first disclosed in late September 2016. This post discussed how the company’s FCPA scrutiny presented an interesting, albeit early, FCPA case study as to the FCPA’s many “ripples.” (See here for the article “FCPA Ripples“).

The case study has become all the more interesting given that Cognizant recently disclosed: “in 2016, we incurred $27 million in costs related to the FCPA investigation and related lawsuits. We expect to continue to incur expenses related to these matters in 2017 and future periods.”

The question ought to be asked: is Cognizant “boiling the ocean”?

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Friday Roundup

Roundup

Firtash extradition, scrutiny alerts and updates, spot-on observation, and refreshing words. It’s all here in the Friday roundup.

Firtash Extradition

In April 2014, the DOJ announced the unsealing of a criminal indictment charging six individuals “with participating in an alleged international racketeering conspiracy involving bribes of state and central government officials in India to allow the mining of titanium minerals.” (See here for the prior post).

Among those charged was Dmitry Firtash, a high-profile Ukrainian businessman.

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Checking In On Wal-Mart’s FCPA And Compliance-Related Expenses

Wal-Mart

In its recent 4Q FY2017 earnings call presentation Wal-Mart disclosed $17 million in Foreign Corrupt Practices Act and compliance related expenses ($12 million for ongoing investigations and inquiries and $5 million for global compliance program and organizational enhancements). The Q4 expenses of $17 million compare to Q3 expenses of $29 million, Q2 expenses of $28 million and Q1 expenses of $25 million.

Doing the math, Wal-Mart’s 4Q FCPA and compliance-related costs is approximately $275,000 per working day.

Over the past approximate 5 years, I have tracked Wal-Mart’s quarterly disclosed pre-enforcement action professional fees and expenses.

While some pundits have ridiculed me for doing so, it quickly caught on as the popular thing to do.

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Friday Roundup

Roundup

Scrutiny alerts and updates, former Bio-Rad general counsel prevails, and light FCPA sentences. It’s all here in the Friday roundup.

Scrutiny Alerts and Updates

USANA Health Sciences

When putting together a list of companies that are likely to become the subject of FCPA scrutiny, small Utah-based companies that sell healthcare products is surely to be at the bottom of the list.

Yet, Nu Skin Enterprises resolved an FCPA enforcement action in 2016 and Nature’s Sunshine Products resolved an FCPA enforcement action in 2009.

In the latest instance of FCPA scrutiny involving this unique group, USANA Health Sciences Inc., a Utah based nutritional company that manufacturers supplements, personal care and healthy food products, recently disclosed:

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Checking In On Wal-Mart

Wal-Mart

In its recent 3Q FY2017 earnings call presentation Wal-Mart disclosed $29 million in Foreign Corrupt Practices Act and compliance related expenses ($24 million for ongoing investigations and inquiries and $5 million for global compliance program and organizational enhancements). The Q3 expenses of $29 million are slightly higher than the Q2 expenses of $28 million.

Doing the math, Wal-Mart’s 3Q FCPA and compliance-related costs is approximately $465,000 per working day.

Over the past approximate 4.5 years, I have tracked Wal-Mart’s quarterly disclosed pre-enforcement action professional fees and expenses.

While some pundits have ridiculed me for doing so, it quickly caught on as the popular thing to do.

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