Walmart’s Global CCO Discusses the Company’s Restructured Anti-Corruption Compliance Program

The high-profile bribery allegations against Wal-Mart Stores (Walmart) put the FCPA in a global spotlight, prompting board members across the country to ask counsel about corruption risks.  The company itself, a global retail behemoth, has been deeply embroiled in a wide-ranging internal investigation since its 2011 SEC disclosure of possible FCPA violations, followed by the 2012 New York Times report that Walmart had paid over $24 million in bribes in Mexico.  The investigation has cost the company upwards of $500 million so far.  Walmart hired Jay Jorgensen as Senior Vice President and Global Chief Compliance Officer to lead the compliance efforts in 2012.  Jorgensen explained the details of Walmart’s new compliance program in a recent interview at the Dow Jones Global Compliance Symposium and discussed the lessons Walmart learned and the challenges that large multi-national companies face in constructing effective compliance programs.  See “A Guide to Disclosing Corruption Investigations in SEC Filings (Part Three of Four)” (May 29, 2013) (tracing Walmart’s disclosures).

To read the full article

Continue reading your article with an ACR subscription.