In a major legal development, a U.S. federal court has dismissed bribery charges against two former Cognizant executives—Gordon Coburn and Steven Schwartz. The decision, issued on April 4 by U.S. District Judge Michael Farbiarz in New Jersey, permanently closes the case, barring any future reopening by prosecutors.

Trump’s Executive Order Alters FCPA Enforcement Landscape

The dismissal follows a renewed motion filed by attorney Alina Habba. She cited a March 2025 executive order from U.S. President Donald Trump, which suspended enforcement of the Foreign Corrupt Practices Act (FCPA) on the grounds that it placed U.S. businesses at a competitive disadvantage overseas.

Previously, in 2024, Judge Farbiarz had allowed a six-month delay to facilitate testimony from critical witnesses, including one whose passport was reportedly held by India’s Enforcement Directorate. However, the legal environment shifted significantly after Trump’s directive.

Background: Allegations of Bribery in Cognizant’s India Expansion

The charges stemmed from a 2016 case in which Cognizant Technology Solutions self-reported “improper payments” made in India. According to various reports, the alleged bribes—amounting to $3.6 million—were approved by Coburn and Schwartz and routed through a third-party construction company, believed to be Larsen & Toubro (L&T).

These payments were allegedly made to obtain government clearances for Cognizant’s 2.7 million square foot IT campus in Chennai in 2014.

Company Settlements and Legal Proceedings

Cognizant reached a $95 million settlement in 2021 to the lawsuit, and in February 2019, paid $25 million to resolve charges brought by the U.S. Securities and Exchange Commission (SEC).

The case led to five class-action lawsuits between October and November 2016, which were later consolidated into one in New Jersey.

Case Closed: Judge Grants Dismissal Without Option to Reopen

Despite earlier judicial hesitation and denial of further trial delays, Judge Farbiarz granted the final dismissal following Habba’s motion. The case, now closed, marks a pivotal moment in the legal and regulatory discourse around U.S. corporate conduct abroad, particularly in light of changing FCPA enforcement.

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