In this special bonus podcast, I am joined by Jay Rosen to discuss the stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the FCPA enforcement action against the world’s largest retailer–Walmart. Some of the highlights include:

• The background facts;
• How significant is the case;
• Is the penalty too low (or too high)?
• Response of Walmart;
• Lessons learned for the compliance professional;
• Was there self-disclosure and full cooperation?
• How should we analyze the monitor requirement under the Benczkowski Memo?

Resources:
The documents for this matter include:
From the Department Of Justice

1. Criminal Information
2. Non-Prosecution Agreement
3. Plea Agreement and Statement of Facts
4. Press Release

From the SEC, aCease and Desist Order and Press Release.
See also Tom’s Blog Post Walmart Enforcement Action-Part 1: Introduction. Tom will have multiple blog posts on the Walmart enforcement action so keep abreast on the FCPA Compliance Report.