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 | Investigations Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Investigations Dataset

 
Investigation into Cognizant's Activities in India · Cognizant Technology Solutions Corporation

Information & Summary

Investigation into Cognizant's Activities in India

Related FCPA Matter:   Cognizant's Involvement in India between 2014 and 2016 Information

Information & Summary

Investigation Name:    Investigation into Cognizant's Activities in India

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:    Unknown

Whistleblower:    Unknown

Summary

Cognizant Technology Solutions Corporation (Cognizant) was a New Jersey corporation whose common stock was registered with the SEC and traded on the NASDAQ. The majority of Cognizant’s operations in India were conducted through Cognizant Technology Solutions India Private Limited, the company's largest subsidiary.

According to its September 30, 2016 8-K filing, Cognizant began conducting an internal investigation into whether certain payments relating to facilities in India were made improperly and in possible violation of the FCPA and other applicable laws. Cognizant’s investigation was conducted under the oversight of the Audit Committee, with the assistance of outside counsel, and focused on a small number of company-owned facilities. Cognizant voluntarily notified the DOJ and SEC and cooperated with both agencies.

On February 13, 2019, the DOJ issued a formal declination pursuant to the agency's FCPA Corporate Enforcement Policy.

On February 14, 2019, the DOJ filed an indictment in the District of New Jersey against former president Gordon J. Coburn and former chief legal officer Steven Schwartz alleging FCPA violations.

On February 15, 2019, the SEC issued a cease and desist order against Cognizant. On the same date, it filed suit against Coburn and Schwartz alleging FCPA violations.

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