In 2019, after having spent over $60 million in investigative costs, Cognizant was ordered by the SEC to pay $25 million in fines for violating the FCPA. […] The complaint alleges that, in the years leading up to the public revelation of the bribery scheme, the Board was made aware of several red flags regarding Cognizant's FCPA compliance. At a September 2014 meeting of the Board audit committee, director defendants Klein, Breakiron-Evans, Mackay, and Wendel learned that a "'weakness' was uncovered in Cognizant's global sub-contracting management process for hiring individual contract workers in India." They were further told that "'there is potential to reevaluate anti-corruption/bribery controls in compliance with FCPA and UK Bribery Acts.'"