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?


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.