FCPA Compliance Report-Live from London, Part III-Cognizant Technology
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:
- The underlying facts of the case.
- How did the company obtain a Declination with Disgorgement in the face of C-Suite involvement?
- What prior FCPA enforcement actions could provide guidance for the resolution in this matter?
- What are the lessons to be learned by the CCO and compliance professional from this enforcement action?
- What are the lessons for Boards of Directors from the Cognizant enforcement actions?