Tagged: declination

Reflections on the Cognizant FCPA Resolution: Does DOJ Mean What it Says? (Part III of IV)

It’s easier to fool people than to convince them they have been fooled. — Mark Twain The only difference between reality and fiction is that fiction needs to be credible. — Mark Twain We live in an era where credibility and truthfulness are character values that are often challenged, questioned and indeed overrun.  Trust and integrity are values of utmost value and importance.  In an...

A Strategy for Non-Disclosure of FCPA Violations

We all understand that issues are not black and white, meaning there are areas of gray when analysis and cost-benefits need to be weighed. Lawyers are regularly identifying legal risks and applying such risks to specific courses of action. Depending on the countervailing considerations, lawyers can recommend moving forward in the face of a specific risk. Much has been written (including on this blog) about...