Does the FCPA Apply to Retailers? Ask Wal-Mart (or Aaron Murphy)


I am often asked the question by representatives of retailing companies of whether the Foreign Corrupt Practices Act (FCPA) applies to their businesses. While I have always answered in the affirmative, this question was succinctly answered this week with an announcement by Wal-Mart that it had initiated an internal investigation related to possible violations of the FCPA. Further, as reported by the FCPA Professor, Wal-Mart announced in a December 8, 2011 10K filing that “The Company has voluntarily disclosed its internal investigation to the U.S. Department of Justice [DOJ] and the Securities and Exchange Commission [SEC].”

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