Tagged: Cognizant FCPA lesons learned

Lessons Learned from the Cognizant FCPA Resolution (Part IV of IV)

Lessons Learned from the Cognizant FCPA Resolution (Part IV of IV)

The Cognizant FCPA enforcement action will go down as a problematic resolution for the policy reasons mentioned in my last post.  Putting those concerns aside, there are some important lessons learned and observations that should be examined. Credit for Pre-Existing Compliance Program: From a compliance perspective, DOJ’s declination letter explicitly credits Cognizant’s compliance program, citing “the existence and effectiveness of the Company’s pre-existing compliance program,...