Tagged: Walmart FCPA

25 Jun, 2019

Lessons Learned from the Walmart FCPA Enforcement Action (Part III of III)

This is a tough posting – frankly, there are so many lessons learned from the Walmart case that they could fill a book, or an e-book at least. I will focus on some of the big issues. Walmart should breathe a sigh of relief. The compliance cloud hanging over its heard for so long is now gone, except with one big caveat – Walmart has...

General

23 Jun, 2019

Thank You, Thank You: DOJ and SEC Resolve Walmart FCPA Enforcement Action (Part I of III)

Our long national nightmare is over – President Gerald Ford, August 9, 1974 So, $900 million and roughly 8 years later, DOJ and the SEC announced the end of the Walmart FCPA enforcement action. (DOJ Here and SEC Here). The Walmart scandal, which was first reported in the New York Times, was a watershed moment in anti-corruption enforcement. It marked a real turning point in...