This trend has already been visible in prior years – as reported on here, in 2019, the DOJ declined to prosecute Cognizant Technology Solutions Corporation (Cognizant) for FCPA violations, but used information provided by Cognizant as part of the company's voluntary self-disclosure to investigate and prosecute the company's former president and former chief legal officer for their involvement in the bribery scheme. Similarly, in 2020, the DOJ specifically credited asphalt company Sargeant Marine, Inc.'s cooperation in agreeing to a 25% reduction in the criminal fine imposed on the company in connection with the company's scheme to pay bribes to foreign government officials in Brazil, Venezuela and Ecuador, while at the same time bringing criminal charges against several Sargeant Marine employees who were involved in the bribery scheme.