In this special bonus episode I visit with Mike Volkov on the Cognizant Technology Solutions Corp FCPA enforcement action, declination and C-Suite criminal indictments which were all announced on Friday of this past week. Highlights from the podcast include:

  1. What were the underlying facts of the case?
  2. How did the company obtain a Declination with Disgorgement in the face of C-Suite involvement?
  3. What prior FCPA enforcement actions could provide guidance for the resolution in this matter?
  4. What are the lessons to be learned by the CCO and compliance professional from this enforcement action?
  5. What are the lessons for Boards of Directors from the Cognizant enforcement actions?

Mike Volkov is running a five-part blog post series on the Cognizant Technology Solutions Corp FCPA enforcement action this week on his award-winning blog site Corruption, Crime and Compliance. You should check it out each day and you can begin by reading Part I, by clicking here.

See also, Matt Kelly’s blog post $25 Million to End the Cognizant FCPA Caseon his Radical Compliance blog.

Additional Resources:

SEC Cease and Desist Order

DOJ Declination

DOJ Press Release

Coburn and Schwartz Indictment