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

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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