Last week Walmart resolved its long-standing Foreign Corrupt Practices Act scrutiny by agreeing to pay approximately $283 million to the DOJ/SEC (see here and here for prior posts). $283 million is $283 million. However, as highlighted in this post (a post informed by FCPA practice experience including conducting FCPA internal investigations around the world and having read and analyzed every FCPA enforcement action in the 40+ year history of the FCPA), the actual allegations / findings…
This prior post went in-depth into the long-awaited Walmart Foreign Corrupt Practices Act enforcement action in which the company agreed to pay the DOJ/SEC approximately $283 million. This post highlights additional issues to consider from the enforcement action. Timeline Walmart was under FCPA scrutiny since approximately mid-2011. Thus, from start to finish its FCPA scrutiny lasted an unconscionable approximate 8 years. There is simply no excuse for this and the DOJ/SEC have long-recognized the issues…
Last week professionals from all over the country and from leading firms and companies came to Minneapolis to elevate their Foreign Corrupt Practices Act knowledge and practical skills at the FCPA Institute – Minneapolis hosted by Dorsey & Whitney. The next stop for the FCPA Institute is Boston on October 3-4 in an event hosted by K&L Gates. Since 2014, the FCPA Institute has elevated the FCPA knowledge and practical skills of approximately 250 diverse professionals…