On February 14, 2019, a federal grand jury returned an indictment charging two former officers of Cognizant Technology Solutions Corporation (“Cognizant”), a publicly traded Fortune 200 technology services company, in connection with a foreign bribery scheme.  The indictment alleged that, in April 2014, the two officers—the company’s former president and chief legal officer—authorized a $2 million payment to government officials in India to obtain the permit necessary to open a new office campus.  The individuals, according to the indictment, then concealed the bribe payment through fake construction invoices.  DOJ declined to prosecute Cognizant, citing its voluntary self-disclosure, cooperation and remediation, and disgorgement to DOJ and SEC of the cost savings from the scheme.

United States v. Coburn and Schwartz, 19-cr-120 (D.N.J.)
DOJ Press Release