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Cognizant Technology Solutions – An Interesting, Albeit Early, FCPA Case Study

cognizant

As highlighted in this prior post, on September 30th Cognizant Technology Solutions disclosed that it voluntarily disclosed to the DOJ and SEC “certain payments relating to facilities in India [that] were made improperly and in possible violation of the FCPA and other applicable laws.”

Even though Cognizant’s FCPA scrutiny is a mere six weeks old, it presents an interesting FCPA case study as to the FCPA’s many “ripples.” (See here for the article “FCPA Ripples“). As stated in the article: “because of the many ripples of FCPA enforcement, it is important that FCPA enforcement be subjected to meaningful judicial scrutiny and that enforcement actions represent legitimate instances of provable FCPA violations, not merely settlements entered into for reasons of risk aversion.”

On this issue, it is interesting to note that Cognizant’s FCPA scrutiny relates to permits in connection with certain facilities in India and you can read all about actual legal authority concerning this type of FCPA enforcement theory in this article.

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Scrutiny Alerts And Updates

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Lost in the shuffle in this active week of Foreign Corrupt Practices Act enforcement has been the following scrutiny alerts and updates.

This post highlights scrutiny alerts and updates concerning: Cognizant Technology Solutions Corp., Misonix, a PDVSA-related matter, JPMorgan and Standard Chartered.

Cognizant Technology Solutions Corp.

The New Jersey-based provider of information technology, consulting, and business process services disclosed:

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