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.  At the same time, the Justice Department announced: (1) its declination under the FCPA Corporate Enforcement Policy; and (2) the indictment of Cognizant's former President and General Counsel for criminal FCPA violations.


In this Episode, Michael Volkov discusses the Cognizant FCPA enforcement action and the lessons learned.