Information technology company Cognizant Technology Solutions Corporation, based in Teaneck, N.J., has reached a $25‑million settlement with the SEC over allegations concerning bribery payments made to advance permit approval for the construction of a 2.7 million-square-foot facility in Chennai, India. The DOJ, mentioning that Cognizant self-disclosed, declined to prosecute, however, civil and criminal FCPA charges against former president Gordon Coburn and former chief legal counsel Steven Schwartz are pending in the District of New Jersey. Given the apparent involvement of high-level executives in wrongdoing, did the company manage to obtain a good deal for itself? See “FCPA Prosecutions and the C-Suite
” (Jan. 9, 2019).