In this Episode 3 of my special Live from London series, Jonathan Armstrong interviews me on the recent on the Cognizant Technology Solutions Corp FCPA enforcement action, declination and C-Suite criminal indictments which were all recently announced. I highlight the significance of the declination for for the compliance professional. Some of the highlights include:

  1. 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?

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