How Cognizant Avoided Charges

Interesting take from the WSJ on how Cognizant (CTSH) avoided charges.

The case of Cognizant Technology Solutions Corp. shows how a company can avoid criminal charges even if its C-Suite was involved in alleged wrongdoing.

Two former Cognizant executives—an ex-president and a former chief legal officer, who oversaw the company’s compliance program—were charged last week for allegedly approving illicit payments to help build a corporate campus in India.

Not facing criminal charges: Cognizant itself. The Teaneck, N.J., company agreed to pay $25 million in disgorgement and civil penalties to settle its role in the case. The Justice Department said the company avoided criminal charges because it voluntarily disclosed the matter within two weeks of learning about it.

The company’s internal investigation, its cooperation, remediation and the presence and effectiveness of Cognizant’s pre-existing compliance program also played a role, prosecutors said in a letter to Cognizant’s lawyers. Cognizant also agreed to cooperate in the Justice Department’s ongoing investigations.

I was impressed by the way Cognizant handled this mess.

Posted by on February 21st, 2019 at 11:20 am


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