Rapid expansion presents great opportunity and great risk.
Tom Fox and Michael DeBernardis go deep into the Walmart bribery case, why immediate cooperation matters, tips for companies to prevent similar problems, the best course of action when working internationally, and projecting risk regardless of industry.
▶️ The Walmart Enforcement action with Tom Fox and Michael DeBernardis.
Key points discussed in the episode:
- Tom Fox lays out the facts of the Walmart case. Michael points out how prevention could have saved millions of investigation costs.
- Rapid expansion presents great opportunity and risk. Tom emphasizes that extensive remediation and cooperation can bring significant credit.
- Michael explains Walmart’s underwhelming conduct. Tom brings up the congressional investigation, leader exits, and the business implications of publicizing.
- Michael shares his advice to avoid Walmart’s case – setting realistic and proper incentives. He also provides hypothetical counsel if he could work with Walmart when the issue broke out.
- Michael highlights the importance of timeliness, engaging with regulators as early as possible, and providing FCPA training when asked.
—————————————————————————-
Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com.
