Last week when the DOJ dismissed its long-standing FCPA enforcement action against former Cognizant Executives Gordon Coburn and Steven Schwartz, I told anyone who would listen that it was wrong to view the development exclusively through the lens of the Executive Order given that the matter had several legal and factual deficiencies.

Since then, the DOJ earlier this week filed a notice to proceed to trial in the FCPA (and related) matter against Smartmatic executives (and others). (See here).

Earlier today, the DOJ filed notices indicating that it “intends to proceed to trial” in two additional, separate FCPA matters.