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The Cognizant bribery scheme is another in the line of illegal conspiracies orchestrated by senior management – but this one is even more disturbing for a number of reasons. Cognizant’s former president and general counsel directed the scheme in full consultation and with full knowledge and intent with the chief
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Tom Fox and I recorded a podcast recently on the Johnson Controls enforcement action. In our podcast we discuss a number of issues relating to the Justice Department’s decision to reward Johnson Controls with a declination. You can listen to our podcast here. It is always a pleasure to
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There’s something happening here, but what it is ain’t exactly clear – “For What It’s Worth,” Buffalo Springfield At first glance, the SEC’s recent enforcement action against Johnson Controls for $14 million for FCPA violations in China, along with a Justice Department declination under its new Pilot
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DOJ’s FCPA Unit knows what they are doing. In the immediate weeks after the release of the FCPA Pilot Program, DOJ publicly released two declination letters for Akamai Technologies and Nortek, Inc. and the SEC announced disgorgement settlements of $671 thousand and $321 thousand, respectively. These two actions, however,