Lessons in Self-Reporting and Cooperation From the Walmart Settlement

Walmart’s $282-million FCPA settlement with the DOJ and SEC has several notable features such as differing cooperation credit for separate regions and an insufficient self-report. On the other hand, charges that Walmart violated the FCPA’s anti-bribery provisions are noticeably missing. In this article, we glean lessons from those elements of the settlement and discuss the enforcement signals this long-awaited high-profile case sends. See “Walmart Finally Settles for $282M and a Monitor” (Jul. 10, 2019) and “Analyzing Walmart’s Unique Monitorship and Its Compliance Failures and Fixes” (Jul. 24, 2019).

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