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The Many Issues To Consider From The Cognizant Technology Enforcement Action

Issues

Previous posts here and here highlighted the recent Foreign Corrupt Practices Act enforcement action against Cognizant Technology Solutions and two of its former executives.

This post continues the analysis by highlighting several issues to consider.

Timeline

As highlighted in this prior post, Cognizant disclosed its FCPA scrutiny in a September 2016 SEC filing. Thus from start to finish, Cognizant’s FCPA scrutiny lasted approximately 2.5 years. While 2.5 years is shorter than recent medians of over 4 years (see here), 2.5 years is still too long for FCPA scrutiny to last.

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Friday Roundup

Roundup

Transparency, hilarious, fact-checking, little sense, just saying, and for the reading and listening stack. It’s all here in the Friday roundup.

Transparency

The Project on Government Oversight (POGO) recently this document titled “Baker’s Dozen: 13 Policy Areas That Require Congressional Action” noting that a “lack of transparency around enforcement of the FCPA leaves lingering questions about its utility.” POGO then proposes:

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Five Years Later, Bilfinger Emerges From DPA – Transparency Nil

emerge

As highlighted in this previous post, in 2013 Germany-based Bilfinger resolved a Foreign Corrupt Practices Act enforcement action concerning conduct in Nigeria by agreeing to pay approximately $32 million. The enforcement action was resolved via a three-year deferred prosecution agreement and the company was required to engage a monitor for an 18 month period.

In September 2016, the DPA was extended because, in the words of the DOJ, of “the monitor’s inability to certify compliance with the compliance obligations in the 2013 Agreement after 18 months of monitorship.” In pertinent part the extended DPA stated:

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Friday Roundup

Roundup

Elevate, further to the clustering phenomenon, transparency, dismissed, and incomplete. It’s all here in the Friday roundup.

Elevate

Learning a new topic or elevating your knowledge and practical skills in a topic is not just for formal students in formal educational settings. Professionals in the workplace can also benefit from back to “school” experiences.

For professionals in the FCPA space – or wishing to join the FCPA space – the FCPA Institute serves this objective and has “graduated” approximately 200 hundred diverse professionals since its launch in 2014.

The next FCPA Institute will take place in Nashville on May 3-4th. See here to learn more and to register.

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