News & Analysis as of

Wal-Mart Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA)

The Volkov Law Group

2019 FCPA Enforcement Highlights (Part II of III)

The Volkov Law Group on

In a record year, there are bound to be numerous interesting enforcement actions and principles.  I picked out a few to highlight....more

The Volkov Law Group

FCPA 2019: A Record Year in Enforcement and Compliance (Part I of III)

The Volkov Law Group on

Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices....more

Thomas Fox - Compliance Evangelist

Top Five Department of Justice FCPA Enforcement Actions in 2019

Welcome to the 2020’s. The past decade helped shape both Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. 2019 FCPA enforcements bore out many of the developments from the preceding years of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

Porter Hedges LLP

Alert: "DOJ And SEC Reach Settlement With Walmart For FCPA Violations"

Porter Hedges LLP on

The Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on June 20, 2019 that Walmart, Inc. (“Walmart”) agreed to pay a combined total of $282.7 million to resolve the years-long...more

Thomas Fox - Compliance Evangelist

Friday Compliance Potpourri

It has continued to be quite a couple of weeks in the Foreign Corrupt Practices Act (FCPA) world. Last week was the announcement of the long-awaited Walmart Inc. (Walmart) FCPA resolution. The pundits were out in force this...more

The Volkov Law Group

Lessons Learned from the Walmart FCPA Enforcement Action (Part III of III)

The Volkov Law Group on

This is a tough posting – frankly, there are so many lessons learned from the Walmart case that they could fill a book, or an e-book at least.  I will focus on some of the big issues....more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 4 – What Does it all Mean?

I am at the end of this exploration of the Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action. This massive case came in with multiple documents, a long list of instances of bribery and corruption,...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 3-The Penalties and Remediation

The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced last week. This massive case came in with multiple documents, a long list of instances of bribery and corruption, a...more

The Volkov Law Group

Walmart’s Recipe for Corruption Disaster: Rapid International Growth without a Compliance Program Foundation (Part II of III)

The Volkov Law Group on

The Walmart case, from a big picture standpoint, represents a serious warning to all global companies committed to rapid international growth.  In the absence of a significant and sustained commitment to compliance, rapid...more

The Volkov Law Group

Thank You, Thank You: DOJ and SEC Resolve Walmart FCPA Enforcement Action (Part I of III)

The Volkov Law Group on

Our long national nightmare is over – President Gerald Ford, August 9, 1974 - So, $900 million and roughly 8 years later, DOJ and the SEC announced the end of the Walmart FCPA enforcement action.  (DOJ and SEC). The...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 2 – The Bribery Schemes

The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced last week. This massive case came in with multiple documents, a long list of instances of bribery and corruption, a...more

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

Burr & Forman on

June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 80, The Last Jedi Edition

Jay and I return for a wide-ranging discussion on some of the top compliance- and ethics-related stories of the week, including: 1. There are several FCPA 40th anniversary pieces going up these days. The FCPA Blog is looking...more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - December 2017

Dorsey & Whitney LLP on

Deputy Attorney General Rod Rosenstein announced the addition of a new Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) policy, titled the FCPA Corporate Enforcement Policy. The new policy, which was...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 77, the Home for the Holidays Edition

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, including: 1. The DOJ/SEC FCPA Guidance turned 5 years old this week. For the compliance practitioner, it...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 56

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations and White Collar Defense - June 2016

Eye on the Supreme Court—Corruption and Fraud Edition - Why it matters: This session, the Supreme Court has undertaken the review of numerous cases that raise thorny issues arising in the white collar context. In our...more

Thomas Fox - Compliance Evangelist

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 1

In this initial This Week in FCPA, Episode 1, Jay Rosen and I review this week's happenings in the world of FCPA. Today we discuss the 4th anniversary of the New York Times story about Wal-Mart in Mexico, the Harder guilty...more

BakerHostetler

Foreign Corrupt Practices Act 2015 Update

BakerHostetler on

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for August 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations & White Collar Defense - June 2015

The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card? - Why it matters: The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing...more

Thomas Fox - Compliance Evangelist

Why Should Americans Care About the FIFA Indictments? Part III – Corruption and US Companies

Today, I continue my four-part series on the above question posed to me recently by a colleague. In Part I, I wrote that only the US government had the wherewithal, tools and will to do so. Yesterday, I focused on corruption...more

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