Tagged: SEC FCPA

Cognizant Technology Pays $25 Million for FCPA Violations and Earns Declination — Two Executives are Indicted for Criminal FCPA Violations (Part I of IV)

In the first corporate FCPA action of 2019, Cognizant Technology Solutions Company settled its long-running FCPA case, agreeing to pay the SEC $25 million.  (SEC Settlement Here).  At the same time, the Justice Department announced: (1) its declination under the FCPA Corporate Enforcement Policy (Here); and (2) the indictment of its former President and General Counsel for criminal FCPA violations (Here). The charges arose from...

Eletrobras Settles SEC FCPA & Bid-Rigging Enforcement Action for $2.5 Million

In a December 2018 enforcement settlement, the SEC and Brazil’s Centrais Elétricas Brasileiras S.A. (“Eletrobras”) agreed to violating books and records and internal accounting controls requirements and paid a $2.5 million penalty.  (Here). DOJ declined to prosecute Eletrobras. Eletrobas stock is traded on the New York Stock Exchange.  The Brazilian government owns 51 percent of Eletrobras and appoints seven of eleven board members. The bribery...

Stryker Suffers “Strike Two” and Settles SEC FCPA Case

Stryker Corporation has suffered a second FCPA enforcement action, and will now bear the stigma of FCPA “recidivist.”  In reaching a settlement with the SEC and agreeing to pay a $7.8 million civil penalty, Stryker will now be subject to an SEC-imposed compliance monitor.  (Here). Stryker’s recent set of violations surrounded books and records violations and deficient accounting and compliance controls in India, China and...