Originally published in Law360, New York (April 23, 2012, 9:40 PM ET)

Wal-Mart Stores Inc. and some of its executives may face criminal charges and millions of dollars' worth of civil penalties in the wake of a report that the retail giant paid $24 million in bribes to facilitate the breakneck expansion of its Mexican operations and shut down internal investigations into the matter, experts say.

Given the U.S. Department of Justice's push to pursue tough penalties against companies in Foreign Corrupt Practices Act cases, detailed allegations in the New York Times on Sunday that some of the retailer's highest-ranking executives refused to conduct a comprehensive investigation into the company's fastest-growing foreign subsidiary — and instead promoted Wal-Mart de Mexico SAB's CEO to vice chairman of the U.S. business — could cause big problems for the company, attorneys say.