Cognizant FCPA lesons learned

General

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