Since 2019, this site has followed the Foreign Corrupt Practices Act enforcement action (DOJ and SEC) against former Cognizant Technology Solutions executives Gordon Coburn and Steven Schwartz in connection with an alleged bribery scheme in India.
This February 25th post set forth the many reasons (legal and factual) why the enforcement action was unusual.
In April, the DOJ finally did the right thing and dismissed the indictment ending the DOJ enforcement action. (See here for the prior post).
Yesterday, the SEC also finally did the right thing.
This SEC release states:
“The Securities and Exchange Commission … filed a joint stipulation with Defendants Gordon J. Coburn and Steven E. Schwartz to dismiss, with prejudice, the Commission’s ongoing civil enforcement action against them.
The Commission’s decision to exercise its discretion and dismiss the pending enforcement action rests on its judgment that the dismissal is appropriate as a policy matter, not on any assessment of the merits of the claims alleged in the action. Furthermore, as stated in the joint stipulation, the Commission’s decision to seek dismissal of this action “does not necessarily reflect the Commission’s position on any other case.”
