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 | Investigations Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Investigations Dataset

 
Investigation into Walmart's Activities in Multiple Countries · Walmart Inc.

Information & Summary

Investigation into Walmart's Activities in Multiple Countries

Related FCPA Matter:   Walmart Inc.'s Involvement in Multiple Countries Information

Information & Summary

Investigation Name:    Investigation into Walmart's Activities in Multiple Countries

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:   

  • Mexican Law Enforcement Agency

Whistleblower:    Yes

Summary

Walmart Inc. is an American multinational retail corporation that operates a chain of hypermarkets, discount department stores, and grocery stores. It is incorporated in Delaware and headquartered in Arkansas. Its stock is traded on the New York Stock Exchange.

Following an internal review of its anti-corruption compliance policies, procedures, and internal controls, Walmart discovered possible issues related to the company's compliance with the FCPA. The Audit Committee of the board of directors then hired outside counsel and other advisors to institute an internal investigation into alleged violations of the FCPA by certain of its foreign subsidiaries, including Wal-Mart de Mexico, S.A.B. de C.V. Walmart later expanded its investigation to include possible FCPA violations in other foreign markets, including Brazil, China, and India.

In early 2011, a former Walmart employee disclosed information about potential FCPA violations in Mexico to a reporter at the New York Times, and prior to publication of an article, the company voluntarily disclosed the investigation to the SEC and DOJ in November 2011. Both agencies then began their own investigations. In addition to voluntarily disclosing the company's internal investigation to the government, Walmart also reported that it was cooperating with both agencies, and its subsidiary Walmex was cooperating with the Mexican authorities. Walmart also then began remedial measures to improve its anti-corruption compliance policies and procedures.

In November 2017, Walmart disclosed that its negotiations with the DOJ and SEC had progressed sufficiently to accrue $283 million in anticipated settlement costs.

On June 20, 2019, both the DOJ and SEC announced enforcement actions against Walmart.

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