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Walmart’s half-billion-dollar FCPA spend

Walmart Inc. said it has spent $439 million in legal fees and other costs associated with investigations of alleged FCPA violations and revamping its global compliance protocol.

The retailer’s fiscal 2014 Global Compliance Program Report was released in April in the wake of allegations of bribery and corruption associated with expansion efforts in Mexico, India, Brazil and China.

In April 2012, the New York Times reported in a Pulitzer Prize-winning story that the company’s Mexico unit paid $24 million in bribes to speed up licensing and permitting for new stores. The paper said top managers in the United States covered up the bribery after learning about it.

A year ago, the board’s audit committee established compliance objectives for the fiscal year ending January 31, 2014.

The Global Compliance Program Report lists the initiatives, which include: 

  • A new global chief compliance officer was appointed in October 2012, and the company’s compliance and legal functions were separated. Walmart said $100 million will be spent on additional, full-time compliance personnel and new financial controls over the course of the next several years.
  • Fourteen responsibilities and risk areas were identified as part of the mandate for the newly independent compliance function, including antitrust, anti-corruption, anti-money laundering, labor, environment, privacy, food safety, and permits and licenses.
  • A global escalation and review process was added to ensure that certain categories of allegations are brought quickly to the attention of the company’s Global Ethics Office at Walmart’s headquarters in Bentonville, Arkansas. 
  • A portion of the compensation for the company’s most senior executive officers is now subject to the achievement of adequate progress on the company’s new compliance objectives.

Walmart said in February it expects to spend between $200 million and $240 million on FCPA-related matters and compliance for fiscal 2015.

It said it will prepare a compliance report for fiscal 2015 as well.


Julie DiMauro is the executive editor of FCPA Blog and can be reached here.

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1 Comment

  1. Big corporations are a danger to democracy. We see it in the USA-a partisan bill on unemployment benefits cant pass because of 1 man. Behind the refusal will probably be lobbyists who want that welfare/bread and butter bill to include the approval of a pipeline-sad but true.

    I thought big corporations like Standard Oil is a thing of the past, but with the supreme court supporting companies and allowing them to participate in elections, they have taken over government-Sad day for democracy.

    Wall Mart inter alia is killing Americans-they can and will not raise the minimum wage to $10.00 in DC-trying living in DC, VA or MD at that wage -we are going backwards…

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