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Dismissal of FCPA Charges Against Ex-Cognizant Execs Sends Early Sign That SEC Will Follow DOJ’s Lead
Reprinted from: Corporate Compliance Insights | 08/13/2025Cadwalader partners Gina Castellano, Martin Weinstein and Laura Perkins recently authored an article in Corporate Compliance Insights, “Dismissal of FCPA Charges Against Ex-Cognizant Execs Sends Early Sign That SEC Will Follow DOJ’s Lead.”
In the article, the authors recount the SEC’s six-year bribery case against two former Cognizant Technology Solutions executives, which ended with the SEC voluntarily dismissing its action in July 2025 after the DOJ had done the same three months prior. The SEC described the move as a policy-based decision— not one based on the merits— which the authors argue signals the SEC’s increasing alignment with DOJ FCPA enforcement priorities under the current administration.
The article also discusses the complex litigation history, the executive order pausing FCPA enforcement and the significance of the dismissals for future SEC enforcement.
Read the full story here.
