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Former Cognizant Technology Solutions Executives Criminally And Civilly Charged In Connection With Indian Planning Permit – Company Resolves $25 Million SEC Enforcement Action

By on February 15, 2019 in 2019 Enforcement Actions, Cognizant Technology Solutions, DOJ Enforcement Action, Executive Enforcement Action, Gordon Coburn, India, Individual Enforcement Action, Permits / Licenses / Customs / Tax, SEC Enforcement Action, Steven Schwartz
coburnschwartz

In this 2016 post highlighting Cognizant Technology Solutions’s disclosure of Foreign Corrupt Practices Act scrutiny it was also noted that Gordon Coburn resigned from his position as President of Cognizant Technology Solutions. This follow-up post noted that the two disclosures were likely related.

Sure enough as today the DOJ announced that Coburn and Steven Schwartz (Executive Vice President, Chief Legal and Corporate Affairs Officer) were criminally charged with FCPA violations. If the defendants choose to put the DOJ/SEC to its burden of proof, disputed issues will likely focus on corrupt intent, obtain or retain business and the facilitating payments exception.

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Friday Roundup

By on November 9, 2018 in Cognizant Technology Solutions, Dmitrij Harder, FCPA Jurisprudence, FCPA Sentences, Goldman Sachs, Vantage Drilling
Roundup

Affirmed, very distressing, scrutiny updates, and for the reading stack. It’s all here in the Friday roundup.

Affirmed

As highlighted in this previous post, in July 2017 Dmitrij Harder was sentenced to 60 months (5 years) in federal prison and also ordered to forfeit $1.9 million after pleading guilty to two counts of violating the FCPA for “bribing an official at the European Bank for Reconstruction and Development (EBRD).”

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A Few FCPA Related Securities Fraud Claims Are Allowed To Proceed

By on September 12, 2018 in Cognizant Technology Solutions, Odebrecht, Related Civil Litigation
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This recent post highlighted how securities fraud class actions in the aftermath of Foreign Corrupt Practices Act enforcement actions or mere instances of FCPA scrutiny are frequently dismissed.

This remains a true statement, but as highlighted in this post, sometimes a claim or two does advance past the motion to dismiss stage as was recently the case in matters involving Cognizant Technology Solutions and Obebrecht.

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Roundup Of Scrutiny Alerts And Updates

By on March 2, 2018 in Albemarle Corp., Applied Energetics, Cognizant Technology Solutions, Exterran Corp, FCPA Investigative Costs, Fresenius Medical Care, Investigative Fees, Merger Issues, Monitor, Orthofix International, Stericycle, World Fuel Services
scrutiny alert

Add some to the list, take a few off, future settlement, continuing to seemingly “boil the ocean,” and monitor costs.

This time of year is heavy on annual reports and other corporate disclosures and this post rounds up various scrutiny alerts and updates.

Albemarle Corp.

The North Carolina based chemical company recently disclosed:

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Friday Roundup

By on November 3, 2017 in Airbus, Cognizant Technology Solutions, Core Labs, Declination Decisions, FCPA Inc., FCPA Investigative Costs, Investigative Fees, ISO 37001, Rogue Employees, SEC
Roundup

Funny headline, just plain silly, new SEC FCPA Unit Chief, parallel, scrutiny alerts and updates, company continues to “boil the ocean,” and ISO 37001 related. It’s all here in the Friday Roundup.

Funny Headline

This Global Investigations Review post contains the headline “Former FCPA Unit Chiefs Defend the ‘Revolving Door’”.

That’s funny. I suppose if I moved from a government enforcement attorney position to a multimillion dollar position in FCPA Inc. defending companies against the enforcement climate I helped create, I might defend the practice as well.

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