Anti-corruption attorney Ronak D. Desai warns that a recent $25 million settlement between Cognizant Technology Solutions and the SEC resolving bribery allegations in India is an effective reminder that traditional FCPA enforcement against U.S. companies and their executives is still a concern, and underscores the immense corruption risk India poses to foreign companies conducting business there.

Many experts expected FCPA prosecutions to fall under the current administration, and others wondered whether the statute would be used increasingly to target foreign companies as a way to advance the president’s “America first” agenda.

This case demonstrates that enforcement against U.S. companies remains a real possibility. And despite the appeal of India’s anglophone democracy as a market, its culture of corruption poses an equally real risk.

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