Separate E-mails In Same Bribery Scheme Are Separate “Units Of Prosecution”

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In the recent indictment of Cognizant Technology Solutions executives Gordon Coburn and Steven Schwartz on various FCPA offenses, the judge ruled that separate e-mails – even if in connection with the same alleged bribery scheme – constitute separate violations of the FCPA’s anti-bribery provisions. Citing mail and wire fraud statutes for precedent, the judge stated […]
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