In the more than four years since Walmart’s Mexican bribery scheme was reported in The New York Times, the company has incurred sky-high expenses responding to the allegations and has revamped its compliance program. Although it has not yet reached an FCPA settlement with the government, it has recently prevailed in a string of shareholder actions in Arkansas related to the misconduct. In Cottrell v. Duke, the 8^th Circuit affirmed the district court’s dismissal of shareholders’ consolidated derivative claims against the board. We analyze the court’s holding that the plaintiffs failed to adequately plead facts showing that a demand on the board to bring a suit would have been futile, and examine the effects the shareholders’ allegations had on the company. See “The Fallout From Walmart’s Ongoing FCPA Investigation” (Jun. 25, 2014).